IMC rating - press briefing

[Fuji Abound]

I understand the CAA will be holding a press briefing at CAA House, Kingsway on the 22 January with regards the IMC rating and FCL more generally.

I will add more information shortly.

[Fuji Abound]

I wanted to add to my earlier post.

This meeting is a joint initiative by EASA and the CAA and both will be represented.

It is not open to the public, but the briefing will be reported in the public domain - in other words on here.

This briefing may provide the first clear indication of how EASA see a number of key FCL issues paning out, including the status of the IMC rating.

It is important to emphasise that this will form part of the scene setting prior to the public consultation which will follow. Whatever view EASA have at this stage is far from set in stone.

It is terribly important that we are all prepared to respond during the consultation period.

I have now had a reasonable volume of feedback from Europe. I can report that I am in no doubt there is a pronounced lack of understanding of the IMC rating by the majority in Europe involved with this process. It has never been more important to ensure that we educate Europe as quickly as possible.

[FullyFlapped]

Fuji,

Do you know which press will be present ?

[Fuji Abound]

Yes, all the usual GA magazines and a number of the representative bodies.

[Fuji Abound]

I am pleased to be able to tell you that we (the IMCr campaign) will be attending the joint CAA EASA press briefing by very kind invite so we are well placed to let everyone know the outcome.

[englishal]

Well done!!

[BEagle]

Good to hear that!

See you there!!

[Contacttower]

I am pleased to be able to tell you that we (the IMCr campaign) will be attending the joint CAA EASA press briefing by very kind invite so we are well placed to let everyone know the outcome.


We look forward to hearing about it...well done and thank you again Fuji for your efforts. :ok:

[dublinpilot]

Yes, well done Fuji for bringing the issue to a head. You've brought it to a point, where EASA realise it can't be done away with quietly in a dark cosy office without a backlash. Well done. :ok:

dp

[David Roberts]

I've posted this on 'the other forum'

Graham Newby (LAA CEO) will be there, also representing the GA Alliance. Graham is on the MDM.032 group with myself.

Eric Sivel, from the Rulemaking Division of EASA, will be speaking for EASA. Eric (Fr) is a fluent English speaker – he was educated in the UK.

The CAA rep on the EASA FCL.001 group spoke in favour of the IMCR at the last FCL.001 meeting 19-20 Dec.

It has been reported to me by a close (mainland Europe) colleague who supports the UK position that at that Dec meeting “it was agreed by EASA, UK and the FCL team that the UK CAA should use the article 10 of Regulation 1592/2002 and file an exemption, to be used for a full four-year transition period, during which the UK IMC Rating would be kept valid, but limited to UK airspace. During that period, the IR Rating will be reviewed, amended to meet the requirements for the PPL level. It should be possible to merge the IR Rating and the IMC Rating, finally granting grandfather rights to the holders of the IMC Rating, hopefully giving them the right to operate in IMC and all airspace, in IMC operating in accordance with IFR.”

A new rulemaking action at EASA is necessary for this, and should be started soon.

Let’s see what is proposed on the 22nd. Unfortunately I shall not be able to attend, as I am away from the w/e.

[D SQDRN 97th IOTC]

which suggests that if you've got an IMCr attached to your PPL, if you can wait 4 years, you will get grandfathered into a PPL / IR ?

[IO540]

Yes, but that is meaningful only if there is a reasonably accessible PPL/IR, like the FAA one for example. Accessible to the typical busy professional person who is the most common IFR owner/pilot. As opposed to the young unemployed young men who make up the bulk of ATPL candidates but who would never have the budget to become private IFR pilots.

Currently, you can achieve a training hours credit in a roundabout way:

Get the JAA PPL/IMCR
Get an FAA PPL/IR (credit is given for all UK VFR and instrument time)
Get a JAA IR (flight training goes down from 50/55hrs (SE/ME) to 0-15hrs)

The gotcha is that you still have to sit all the JAA ground exams. These are full of irrelevant crap and are responsible for so few people doing the JAA IR. Well, there is a bunch of other factors which combine to make the JAA route a right pain, and the JAA audiogram is a significant factor for many, but the ground school is the #1 problem.

Recent history (of attempts to do this) suggests that reducing the ground school to something actually relevant is going to be a major major political nut to crack. A recent attempt, shelved in 2007, ran in committee for about two years and managed to reduce it by about 25%...

When you realise the dead obvious solution, which would do away with the whole issue, would be to accept FAA FCL and certification, you can see how steeped in politics this whole game is. This would wipe out the N-reg scene without a single complaint and establish a very good platform for both flight and maintenance/upgrades. This is politically impossible, however.

[dublinpilot]

“it was agreed by EASA, UK and the FCL team that the UK CAA should use the article 10 of Regulation 1592/2002 and file an exemption, to be used for a full four-year transition period, during which the UK IMC Rating would be kept valid, but limited to UK airspace. During that period, the IR Rating will be reviewed, amended to meet the requirements for the PPL level.

I think EASA is trying to sell the UK pilots a pup here. Give them 4 years to get used to the idea that the IMCr is going, and all will be fine. :rolleyes:

Does anyone really believe that the IR will be reviewed enough to make it anywhere nearly as accessable as he IMCr?

dp

[BEagle]

Other potential gotchas:

1. It may well be that many current RFs will not be permitted to conduct training for the 'EU IR'.

2. Why do they keep saying 'PPL level'? Do they think that, for example, ATPL holders with IR/MPAs will be unable to include a 'EU IR' in their licences?

3. It is unlikely that the death grip on IR testing by CAA Staff Examiners will be loosened. So, whereas for a UK IMCR your friendly local UK/FE(PPL) may conduct the initial test, it is likely that for the 'EU IR' a CAA Staff FE will be required. This will reduce income for many RFs and UK/FE(PPL)s and increase costs for the aspirant 'EU IR' holder.

4. Exams. Currently, UK IMCR trainees can self-study, then take a single exam at their local RF. I really don't see much chance of this under emergent eurocracy - and any change will undoubtedly increase costs to the aspirant 'EU IR' holder.

[tmmorris]

And presumably instructors will need to be IRIs, whereas (as I understand it) IMCR instructors don't require any training as such, other than holding an IMCR or IR themselves.

Is that right?

Tim

[julian_storey]

When you realise the dead obvious solution, which would do away with the whole issue, would be to accept FAA FCL and certification, you can see how steeped in politics this whole game is. This would wipe out the N-reg scene without a single complaint and establish a very good platform for both flight and maintenance/upgrades. This is politically impossible, however.

FAR too sensible :rolleyes:

[TheOddOne]

Does anyone really believe that the IR will be reviewed enough to make it anywhere nearly as accessable as he IMCr?

Certainly not and nor should it be!

I'd have thought that after all the thousands of words written on the various threads covering this subject that everyone would have finally cottoned on to the fact that the UK IMCR and ANY form of IR involving IMC flying in Class 'A' airspace are VERY different animals.

'Accessible' shouldn't mean 'easy'. The IMCR requires a certain level of commitment to theory study but I do think that an IR does require a greater understanding and demonstration of that understanding of the subject than is required or needed for the IMCR. With our present system, that means more in-depth study and exams, I can't think of a different way of doing it.

I don't think that Grandfather rights for an IR from an IMCR is appropriate. Decent credit against further training and theory study, absolutely!

TheOddOne

[S-Works]

Can we just be clear here Fuji, are you claiming that the press conference is a result of your campaign?

Just curious.

[TheOddOne]

FAR too sensible

Julian,

That's the most horrible pun I've seen in ages.

TOO

[TheOddOne]

And presumably instructors will need to be IRIs, whereas (as I understand it) IMCR instructors don't require any training as such, other than holding an IMCR or IR themselves.

Is that right?


No. I can't instruct for the IMCR, only the basic 1-hour required for the PPL. In order to do IMCR instructing, in addition to holding an IMCR, I need to do a further period of training to teach 'applied instrument flight'. It's on my list, but not near the top at the moment.

If a new EASA IR appears then I would expect that in order to teach it, I'd have to hold the rating myself AND receive appropriate training in how to teach it.

TheOddOne

[BEagle]

Who cares what brought about the Press Briefing? The important fact is that it is being held!

I would go along with those statements made by others concerning IFR flight in Class A - which is why my Class 2 IR proposal (based on the CAA's original concept for an EU IMCR) proposes only flight in 'permitted' airspace - and leaves the definition of what is and isn't 'permitted' to national airspace authorities. Because airspace categorisation currently varies from nation to nation and there is no indication that EU-wide airspace harmonisation is as yet on the near horizon.

[Islander2]

Can we just be clear here Fuji, are you claiming that the press conference is a result of your campaign?Oh for gawd's sake, bose-x, who cares!:ugh:

Both of you are devoting significant amounts of time without remuneration to try to preserve a rating that's hugely important to the future of UK GA. Most of us are, I'm sure, very grateful to you both for that but couldn't give a damn about your demeaning playground squabble.

which is why my Class 2 IR proposal (based on the CAA's original concept for an EU IMCR) proposes only flight in 'permitted' airspace - and leaves the definition of what is and isn't 'permitted' to national airspace authorities

BEagle, that's an elegant proposal but no doubt way too pragmatic! Do you know if got as far as EASA committee?

[FullyFlapped]

Can we just be clear here Fuji, are you claiming that the press conference is a result of your campaign?



Obviously there's something wrong with my PC, because I can't find any reference to Fuji saying anything of the sort ...

Give it a rest, matey ... it's getting tedious now ! :=

I don't know who David Roberts is, but if his report is anywhere near being accurate, then this is brilliant news. I don't read it to suggest that anyone with an IMC will automatically be granted the rights of someone with a full IR : rather, I think it suggests that IMC holders will be presented with an opportunity to upgrade to IR rights by virtue of a reasonable amount of further training - which is all I, for one, have ever been after. Let's hope he's right.

[Fuji Abound]

May I also draw your attention please to an important report that will be put before Eurocontrol on the 24th January which specifically looks at Flight Information Services outside CAS which of course substantially relates to GA and their needs. Representatives from EASA will be attending this conference and so will we.

I think this report will be well worth reading and hopefully we will be able to place a copy or links at www.ukimc.org

I have also had some excellent feed back from a number of aircraft manufacturers who have recognised the loss of revenue which will result if there is a shift in demand to VFR only aircraft.

It would be wrong to pre-empt the forthcoming press briefing, as interesting as it is to speculate what is likely to be announced, however there is the suggestion that the IMC rating could become a stepping stone to an EASA IR. For some this could be beneficial, however I firmly believe that for many the IMC rating is sufficient in itself. There are many GA pilots who don’t consider the IMC rating to be a poor man's IR - or certainly this is the exclusive feedback we have had. They see it as a rating which achieves exactly what it sets out to do, and which meets their needs.

If this view is one of consensus I believe it is important that we promote this message.

[IO540]

When EASA is assembling a committee whose scope will include GA related stuff, they invite two GA reps on it, who are AOPA and European Air Sports. I don't know the history/reasons but this is what happens.

David Roberts represents EAS.

You can look at the EAS website and make your own judgement of their position. It is not trivial to work out, especially when it comes to instrument privileges.

Please don't take this the wrong way, Theoddone, but your experience of private IFR (airways) flight around Europe, as evidenced by the following

No. I can't instruct for the IMCR, only the basic 1-hour required for the PPL. In order to do IMCR instructing, in addition to holding an IMCR, I need to do a further period of training to teach 'applied instrument flight'. It's on my list, but not near the top at the moment.


does not exactly provide a lot of support for this point of view:


I'd have thought that after all the thousands of words written on the various threads covering this subject that everyone would have finally cottoned on to the fact that the UK IMCR and ANY form of IR involving IMC flying in Class 'A' airspace are VERY different animals.

'Accessible' shouldn't mean 'easy'. The IMCR requires a certain level of commitment to theory study but I do think that an IR does require a greater understanding and demonstration of that understanding of the subject than is required or needed for the IMCR. With our present system, that means more in-depth study and exams, I can't think of a different way of doing it.



I would suggest that you go up for a few airways flights with a pilot who actually does this (myself for example), do some long legs across Europe, and you will see what nonsense this "the IR must be extra hard" argument is.

The relative ease of airways IFR, especially in the well equipped plane which tends to get used for that kind of mission for fairly straight technical reasons, is one of the best kept secrets of IFR touring :)

I am not suggesting there is the slightest prospect of anybody bringing out an IR which is actually designed for the job in hand - that is a political / vested interest impossibility. But it's a nice mental exercise to think what the syllabus would be like.

This is why it is so easy to tell those who do it on these forums, from those who don't.

[Fuji Abound]

I am not suggesting there is the slightest prospect of anybody bringing out an IR which is actually designed for the job in hand - that is a political / vested interest impossibility.

I wouldn’t give up hope yet.

I think we are all pleasantly amazed at the support the IMC campaign has had, and it continues to grow. We have only just started.

Thank you for your support.

If enough people get behind the campaign and the members of the various representative bodies make it known to their committees that this is something they want we have a really good chance of influencing EASA.

Be in no doubt EASA have a genuine interest in re-writing the rule book. This is therefore a golden opportunity for our collective voice to be heard. The real threat are those who might wish to see the rule booking rewritten based on their own vested interest, a lack of understanding of the issues, or unadulterated complacency.

We must all work together and put to one side any petty bickering or differences - it is too important an opportunity to miss.

[David Roberts]

Fully Flapped, just so you know, I am recent ex Chairman (2000-06) of the BGA, Vice Chairman of the Royal Aero Club, Vice President of Europe Air Sports (EAS - not to be confused with EASA!) and 1st Vice President of European Gliding Union. I was also Chairman of NPLG Ltd, which administers applications for the UK NPPL – SEP and SLMG, from inception in 2002 until last year.

As part of those roles I have spent the last almost six years closely involved with the development of 1592/2002 and EASA, mainly through EAS, EGU (both of which have existed for may years solely to represent their members in EU regulatory matters) and the BGA, and probably (says he modestly!) know more about the workings of the EU system and EASA than most ‘industry’ people outside the agency and the NAAs. I presented the case for all EU air sports / lower weight end of GA at the EU Commission conference on GA in Brussels last March, from which, following a study group this last year which I attended, the intermediate outcome is a ‘Communication’ published last Friday – see
http://europa.eu/rapid/pressReleasesAction.do?reference=IP/08/32&format=HTML&aged=0&language=EN&guiLanguage=en

Sorry, the reference is longer than one line but go to Air Transport portal of the European Commission then general aviation.

On behalf of EAS I led the strategic critique of Part M in Nov 05, which persuaded EASA to take another look at Part M for light aviation (still on-going), have sat on EASA’s MDM.032 working group since inception in March 06, and am involved with the drafting of EU / EASA Implementing Rules and AMCs (Acceptable Means of Compliance) on licensing and operations. This last few weeks I have been reviewing the drafts, to feed back into EASA.

Although primarily a glider pilot I am also a power pilot (though currently lapsed as I have not had enough time to do the hours with all this voluntary work), and I have available to me a large network of people in the aero clubs and pan-EU air sports federations in Europe to call on for expertise and knowledge.

The pan-EU representative groups that have access to EASA provide the industry nominated experts (experts in their own right, not ‘representatives’) for the rulemaking working groups, and which are (in GA) EAS, IAOPA, and ECOGAS. PPL IR is involved now also, and is a member of EAS.

As regards IMCR and IR, this has been a well-known issue at EASA for some time, well before the latest awakening of the risk to IMCR on the UK scene. As has been alluded to in this and other forums, it is not a simple issue on a pan-EU basis. But I genuinely believe EASA recognise the need for a more appropriate level of qualification for our sector of ‘light’ GA, and will try and find a way of bringing it about. There are (EU) legal obstacles to overcome, and of course the vested interests of other (commercial) aviation players.

One key aspect of the EU agenda to always understand is that it is about standardisation not harmonisation. The difference explains much.

[FullyFlapped]

Cor ....... :D

Thanks for your reply, David ;)

[vanHorck]

I've been hesitant to post this, but on balance i feel i should share this.

I have a CAA PPL/Night/IMC/MEP and a Seneca IV. Simply lacking the time for a JAA IR (as well as dreading some of the subjects) I was told by a flight instructor that contrary to popular belief, it is quite legal to fly IFR anywhere in Europe with a CAA PPL combined with an FAA IR, providing the flight is executed in a CAA registered plane (G reg) and the flight is not for commercial purposes.

I asked the CAA for their comment. They did not respond in time (according to their own rules) but on prompting confirmed the above.

I copy the correspondence below. It is a VERY viable alternative to the IMC especially for those also wanting to excersise these privileges abroad .

Regards

Bert van Horck

copy of email:
Dear Mr Van Horck,

Thank you for your e-mail, apologies in the delay of replying. In regards to your query, I can confirm that you may fly IRF on a CAA (G registered) plane with a CAA PPL combined with a FAA IR.

Regards

Personnel Licensing Department

From: Bert van Horck [mailto:[email protected]]
Sent: 24 October 2007 09:59
To: FCLWEB
Subject: could you enlighten me?

I get varied advices on the use of n FAA IR (Instrument Rating) on a G registered plane

The question is simple:

Is it legal to fly IFR on a CAA (G register) registered plane with a CAA PPL combined with an FAA Instrument Rating in British and/or European airspace for private flights (ie not commercial)?

If it is not legal where can I find the legislation that applies?
If I have directed this question to the wrong department, whom should I address it to?

Many thanks,

Bert van Horck

[IO540]

vanHorck

Yes what you describe is correct under ANO article 26.

However the IFR usage is limited to outside controlled airspace i.e. only allowed in Class F/G.

This is sort of OK for the UK where IFR below the airways system is an informal thing anyway (but no IFR flights to Class D airports) but not so good for Europe where IFR flight is normally limited to Eurocontrol routes and all (?) of those are in controlled airspace.

What this does mean is that if you were in say Germany and climbed up or descended through cloud in Class G they would not be able to get you for it. They might be able to get you for flying IFR without an IFR clearance though, but there is no possible IFR clearance in Class G is there?? :)

But in reality nobody (outside the USA) has ever been done for entering IMC under VFR anyway...

[vanHorck]

If there is this limitation, where is it listed?

The question to the CAA was clear: IFR flying in Europe. This means to me without limitations unless otherwise stated.

As both the plane as well as the base license (PPL) is under CAA control, surely they should b the ones to decide the limits and no such limits are referred to in their answer.

You may be better informed on the legalities of this. Where could i find these limitations?

The alternative is I reregister to N-reg but I'd hate to do this....

Thx for your trouble

From tulip country

Bert

[Fuji Abound]

IO

Dont forget the gentleman has a IMC so there is no restriction in UK airspace (other than class A).

It would be interesting to see the exact wording of the question asked.

With some of the replies I have seen they seem to answer part of the question. I am sure the CAA would not want to find themselves in the position where their reply indicates something can be done without caveat as to the limitations. A very interesting debate is likely to arise when the law says one thing and the regulator something else.

[vanHorck]

The exact wording of my question is listed below.

I should add I in no way intend to frustrate the battle for the IMC! In countries with our type of MET (this includes the benelux and the Nordic countries) an IMC is an essential and necessary component to keep the dangers low.....

In fact I even tried to convince the Romanian CAA (where I lived a while) to accept the IMC to fly IFR as VFR flight there for non Romanian registered aircraft requires 48 hours notice to the CAA for permission (prior to a flight plan) but to no avail.....




From: Bert van Horck [mailto:[email protected]]
Sent: 24 October 2007 09:59
To: FCLWEB
Subject: could you enlighten me?

I get varied advices on the use of n FAA IR (Instrument Rating) on a G registered plane

The question is simple:

Is it legal to fly IFR on a CAA (G register) registered plane with a CAA PPL combined with an FAA Instrument Rating in British and/or European airspace for private flights (ie not commercial)?

If it is not legal where can I find the legislation that applies?
If I have directed this question to the wrong department, whom should I address it to?

Many thanks,

Bert van Horck

[Fuji Abound]

Sorry VanHorck I missed you had posted the question as well in your original.

It is interesting the CAA did not caveat their reply.

[IO540]

Bert, It's in ANO article 26. The HTML version is here (http://www.opsi.gov.uk/si/si2005/20051970.htm). There have been amendments to the 2005 version but not relevant to this topic.

It doesn't actually say what you are looking for - the ANO is written as a list of prohibitions rather than a list of privileges and potentially you have to know the entire document to see if anything else affects it. The privileges of the IMC Rating are similarly spread over at least 2 places.

It is possible the CAA man is wrong. This happens occassionally. I know a man who asked the CAA if he could fly a G-reg VFR on an FAA PPL and they said UK ONLY. This is completely wrong; you can fly it worldwide because Article 26 automatically validates ICAO licenses. He sold his plane on the basis of this "advice" and is now a bit cheesed off.

It's also possible the CAA man is right and a lot of people (this topic has been done here many times) have overlooked something.

You could write to the CAA contact again and ask him/her for a clarification on how this is based on the ANO. The answer to that would be most interesting...

[mm_flynn]

It is an interesting reply from the CAA as 26 3) seems to be very specific about rendering valid an ICAO licence (in that it does not allow FI, commercial or IFR in controlled airspace).

It is difficult to think of any basis the CAA could effectively add an IR to a CAA licence based on the pilot holding a rating in some other country (other than the well documented conversion processes) so they must have answered the question from the perspective of having rendered valid the FAA licence.

The answer provided by the CAA is technically correct, but badly misleading as it fails to point out the IFR privilege is only valid outside of A-E (ie. most airspace you are likely to fly IFR in when outside the UK is specifically excluded).

There is a further challenge in that the UK is unique (I believe) in allowing IFR flight (and flight in some IMC) for a basic PPL. Almost every other country has a simple logic of - to file IFR you must have a current IR and you can not fly in IMC without being IFR (and on a clearance or in radio contact). Hence the UK sub IR IFR privileges are probably not valid outside the UK even in Class G airspace. (I am referring here to the rendered valid IRs and the basic PPL IFR capability not the IMCr which is explicitly limited to the UK)

[David Roberts]

There is one other aspect of EU lawmaking and rule making that has a bearing on this whole debate, and which was brought home to me two years go in a meeting.

Although I am not a lawyer, my understanding is this: European law is different to English law; the former seems to require everything you are allowed to do to be written as the law, and ipso facto if it is not written as allowed it is illegal. Hence creating, for e.g., an IMCR for Europe, requires positive statements in law.

Whereas English law is based on the premise that you are allowed to do what you like provided it is not explicitly illegal, and therefore our laws are geared to saying what and how you should do the things you want to do (compliance) and what the penalties are if you transgress.

Any lawyers care to comment?

[BEagle]

As told to me by an Airbus test pilot:

"An Englishman, a German and a Frenchman are given a new aeroplane to fly.

The Englishman looks in the manual to see if there's anything preventing him doing what he wants to do. If there's nothing there, he can do it.

The German looks in the manual to find out how to do what he wants to do. If it's not there, he can't do it.

And the Frenchman?


He merely shrugs and says "Manual? What's a manual?" "

[DFC]

Whereas English law is based on the premise that you are allowed to do what you like provided it is not explicitly illegal, and therefore our laws are geared to saying what and how you should do the things you want to do (compliance) and what the penalties are if you transgress.

Bovine Facees.

Read schedule 8 of ther ANO among other places.

The UK issues a pilot licence which confers privileges on the holder. The holder can exercise those privileges and no more.

Look and whole definition of licence etc etc.

To get that comparison you have to compare European Law (including UK) and the US.

i.e. the FAA issue certificates and doing certain things require certificates not the otehr way round.

------------

BEagle,

The European airspace harmonisationn project is well advanced. All airspace above FL195 is class C for a start.

You can hardly expect any sane person to agree that pilot licensing should be under a single regulation and then let individual states set their own requirements?

Regards,

DFC

[IO540]

David,

Although I am not a lawyer, my understanding is this: European law is different to English law; the former seems to require everything you are allowed to do to be written as the law, and ipso facto if it is not written as allowed it is illegal. Hence creating, for e.g., an IMCR for Europe, requires positive statements in law.

Whereas English law is based on the premise that you are allowed to do what you like provided it is not explicitly illegal, and therefore our laws are geared to saying what and how you should do the things you want to do (compliance) and what the penalties are if you transgress.

I don't believe that is anywhere near the full picture, otherwise it would be illegal to walk down a pavement. No law says you have to walk on a pavement. Similarly, I could fly with no clothes on. No law says I must wear clothes while flying. Law in general must work on the basis of listing what is illegal; as the initial position anyway.

The reason the ANO is unreadable is because it is very badly drafted, partly as a result of years of small amendments intended to plug one "abuse" after another. The U.S. FARs are far clearer but there are still grey areas.

I agree that to create a "Euro IMCR" would require positive legislation, but that is simply because the regs outside the UK (and in the USA) currently require a full IR for any IFR.

A fun point to discuss would be what would have happened if the UK ANO did not contain the words "within the UK" in the IMCR IFR privileges text (actually, I understand, those words appeared only in recent years!) and the UK had filed a difference to ICAO on the Rating.

[BEagle]

fuji - check your e-mails!

[Fuji Abound]

BEagle

Sorry, I cant find an email from you.

Perhaps PM me and I will check those.

:)

[BEagle]

I've re-sent it to [email protected]


......and just had it spat back:

- These recipients of your message have been processed by the mail server:
[email protected] ([email protected]); Failed; 5.4.3 (routing server failure)

So I've tried again with the correct address....hopefully!

[Fuji Abound]

BEagle

The feed from the IMC org is not direct so please PM me if you wish.

Thanks

[moonym20]

Is there any news from this Brief yet? :confused:

[BEagle]

Soon!

I've just got home and am having a bite to eat. But, suffice to say, it was a good meeting and things aren't as gloomy as you might think.

More when I've finished my Golden Palace Special Chow Mein!

[S-Works]

Sorry, edit to point out that this is a cut and paste from Pat Malone editor of GA Magazine who was happy for it to be distributed. I did not realise that there were some too retarded to actually read the text and realise it was cut and paste and therefore expend pages of drivel across the internet sidetracking from the issue as usual.


Most of the talking was done by Eric Sivel, EASA’s head of rulemaking. Ben Alcott, head of PLD at the CAA, was the other speaker. I’m writing it all up for the magazine, but in brief, Ben Alcott stressed how much the CAA supports the IMC rating and has argued for it at EASA (he’s right, too). But the UK is in a minority of one. Nobody else in Europe wants it. The national authorities, often in response to lobbying from airlines and professional pilots’ groups like the European Cockpit Association, are adamant that only an IR can be used for flight in IMC.
Having created this mess, EASA says it’s up to us to resolve it. Charitably, they say they’ll give us as much help as they can. They will arrange for a four-year transition in which the IMC will remain valid while attempts are made to bring the national authorities round to our viewpoint. If they do not come round in sufficient numbers, there is a device, Article 10(5) of EASA’s regulations, which allows a nation to claim an “equivalent safety case” and effectively gain a dispensation to go its own way on the IMC. This, Eric Sivel says, should be a last resort.
EASA’s attitude on this is unedifying; we are having to spend an enormous amount of time, effort and money to make sure nothing happens. There is no guarantee that we can pull it off, even under regulation 10(5). If we ‘file a difference’ the European Commission committee that oversees EASA must give its approval, and it is totally dominated by those who oppose the continuation of the IMC.

[FullyFlapped]

When would this 4-year transition window start ?

[BEagle]

bose-x, that's not quite as I saw it!

After a quick brief from Ben and Eric to set the baseline, the most useful part of the meeting was the Q&A session.

Regrettably, there were some rather emotional comments made at the beginning of the session. But it is understandable and not unreasonable that people should feel free to speak their minds.

Eric, in particular, was a very tolerant speaker - who faced some harsh questioners. He went to great pains to stress that EASA's objective is to Find a European solution before the end of the (JAA to EASA) transition period. Which means that, at least until 2012 (at the earliest) the UK IMCR is safe - and thanks to clarification sought by the CAA, that includes initial issues!

The UK IMCR is most assuredly not dead. EASA and the CAA have stated quite categorically that they will work together to sort this out.

Please believe that EASA is not the enemy! The task of everyone involved in the issue is to work together to address the concerns of those, such as the European Cockpit Association, who have not been properly briefed about the UK IMCR.

I did manage to achieve a very useful point as a 'pack shot'*. I asked Eric whether the opinion of the Vice-President of the European Commission, Jacques Barrot, had any influence on the issue.....

"Well, if Jacques Barrot was against it, we would find it difficult to convince those nations who aren't supportive..."

I then realised that Eric didn't know something I did. Which was only released to www.ukimc.org (http://www.ukimc.org) and others yesterday...

"In which case, I think that the meeting should be aware of the following", I said, then read out significant extracts from this e-mail:

Dear (BEagle),


I'm writing to update you on the latest in our fight to save the IMC Rating.

We had a very productive meeting with Commissioner Barrot. It clarified a number of issues.

Firstly Mr Barrot says that he was committed to retaining a flexible license for light aviation pilots above the minimum safety standards. He was keen to stress his support for the IMC rating. Secondly he committed to a long transition period between the current regime and the reformed EASA-supervised one. Thirdly he agreed that he would consider our recommendation that pilots should be checked by specialised doctors with experience on complaints specific to pilots. The Commissioner agreed that he would ensure that this requirement was left up to each Member State.

The Commissioner agreed to he would keep our office informed on the progress of these and other issues relating to EASA. A public consultation on the issue is planned soon. For updates on this please see the Commission's own Aviation portal at http://ec.europa.eu/transport/air_portal/index_en.htm (BLOCKED::BLOCKED::http://ec.europa.eu/transport/air_portal/index_en.htm)

If you need more, let me know.

Henri Colens





Office of Timothy Kirkhope MEP
Representing Yorkshire & the Humber
in the European Parliament
ASP 14E 264
Rue Wiertz
B-1047 Brussels
BELGIUM

Tel: +32 2284 7321
Fax: +32 2284 9321
Email: [email protected] ([email protected])
Homepage: www.kirkhope.org (http://www.kirkhope.org)





Eric was very pleased to learn of this - it will help greatly towards his efforts to make the nay-sayers understand the level of support which exists towards the UK IMCR.

So, all-in-all, a most useful meeting. The CAA is really on-side at all levels and its perspective is as follows:

EASA-FCL consultation is assumed to start in March 2008.
CAA will explore with EASA avenues to protect the privileges of current IMC rating holders.
CAA will support EASA rulemaking group to review potential for a European solution.
*'Pack shot' is an advertising luvvy's trick to make sure that the name of the product always appears at the end of the commercial and is thus remembered. So, the last point raised at the meeting will usually remain in the sub conscious of the attendees more than any other!

[S-Works]

I don't know about a difference in opinion, everything you have said is in my mail.

However at least I now know who you are Beagle. :O

[julian_storey]

Good work BEagle! :D

[Contacttower]

Great to hear the update, thanks BEagle and bose, do you know what sort of format the 'public consultations' will take?

[Fuji Abound]

Just a brief note from us at the IMCR campaign to say we were at the meeting. We have just been discussing at length the briefing.

Thank you BEagle for a solid summary.

We will update the web site at

www.ukimc.org

over the next few days, and will post further on here and else where.

However, the news is very positive.

Many, many thanks to EASA and to the CAA for taking the intitiative on such an important issue.

[friendly flyer]

bose-x, that's not quite as I saw it!


not how Bose x saw it either!!!


http://http://forums.flyer.co.uk/viewtopic.php?t=40436

[IO540]

Beagle's summary is by far the more accurate of the two above.

I know this as I have just got back from the meeting and a subsequent lengthy discussion with Eric Sivel.

It was most interesting and illuminating.

It was also quite different from any previous presentation I have been to with the likes of CAA or EASA or NATS, most of which I left feeling utterly depressed regarding the future.

There is a very significant change under way and I would describe it mostly positively.

There is substantial work to do, to secure the future of the IMCR (or some equivalent privilege allowing IMC flight without the full IR) after the 4 year extension. But the process for this is reasonably clearly visible and could in fact lead to a Euro-wide privilege.

The greatest danger to GA and specific privileges are some of the GA representatives at the committees, representing narrow vested interests of their own organisation. EASA is very supportive of the matter.

[sternone]

Don't forget that your battle isn't won yet. Despite what these people are 'predicting' it's still the final descission that will be the winner, not all the small victories. I hope you guys make it, but with the feeling i have in Euroland IMCR will never be approved for all of Europe, there are just too many people in Europe scared of GA pilots hopping around in their airspace.

[BEagle]

Good to meet fellow PPRuNers at the meeting. And the value of the www.ukimc.org (http://www.ukimc.org) group cannot be understated!!

But - and it's a BIG but - please, please accept that the UK CAA and EASA regulators are very determined to make the sceptical folk in non-UK €uroland understand the value of the UK IMCR.

It isn't just the non-UK 'GA' groups - in particular it's the Commercial Pilot unions and bodies who must be convinced. We can only do this by:

Getting them to spell out their precise concerns
Addressing each concern sympathetically - but firmly
NOT stating "We Brits know best". That'll get us nowhere!I'm very sure that Timothy Kirkhope's intervention with Commissioner Barrot ( a tres grand fromage de l'EC!) has been a trump card.

I hope my fellow attendees will drop a quick e-mail to the CAA tomorrow to thank them for arranging today's session. As IO540 says, one of the most positive meetings regarding the future that I have had of recent times - and highly encouraging!!

[Fuji Abound]

BEagle

Very, very well put.

Thank you for your support of the UKIMC.ORG but even more importantly thank you to everyone who has supported the camaign AND, even more importantly, for your continued support.

As BEagle says there is still much to be done.

EASA’s attitude on this is unedifying;

On the contrary, I believe EASA is more than demonstrating their support for addressing the needs of GA.

[Edited to add that thanks thus far should also be extended to PPRuNe and BRL for enabling this issue to be so well aired over the last few months and for the sticky]

[Islander2]

A message of support and thanks for all those individuals and organisations that are battling for a pragmatic and sensible outcome on this issue. It's difficult to overstate its importance to the future of UK GA.

[BEagle]

Slight link-glitch in friendly flyer's post - it should be:

http://forums.flyer.co.uk/viewtopic.php?t=40436

Oh - and please let's not stoop to any internecine wrangling - let's work instead on our corporate synergy!

[orionsbelt]

Well done Chaps.
You have represented the true interests of all UK GA flyers today. Very refreshing

How can you all now ensure that you people stay involved and represent our interest rather than allowing the ''Associations''!!!! to take over, as they will surely try to do.

Rdgs Orions***

[Roffa]

You might also think about contacting and trying to get GATCO (http://www.gatco.org/) on side, if you haven't already. They might be able to make representations on your behalf, many of their members will have had (hopefully positive) experiences of controlling IMC rated pilots.

ABOUT THE GUILD

Formed in 1954, The Guild Of Air Traffic Control Officers (GATCO) is an independent professional organisation which exists to promote honourable practice and the highest standards in all aspects of aviation.

It is dedicated to the safety of all who seek their livelihood or pleasure in the air. These ideals have been sustained over the years and GATCO continues to provide a substantial voice for the profession of air traffic control (ATC).

Our membership comprises Civil and Military Controllers and Associate Members including Flight Information Service Officers (FISO) and military Fighter Controllers.

In addition, we have a growing number of Corporate Members who support the aims of GATCO and in turn can benefit from the access to worldwide air traffic control specialists.

Our membership exceeds 2000, providing a wealth of professional and technical expertise which enables GATCO to actively participate in the development of both UK and International ATC.

As such GATCO is recognised and respected worldwide as an influential and professional aviation body.

[justinmg]

A great many people have mentioned the opposition from the commercial pilot sector. ( I suspect that this ,means the ATP group, as the FIs are busy teaching IMC).
If this is the case, perhaps we could mobilise the group of ATPs who currently teach and examine for the IMC, to outline the benefits as they see it. Fight the enemy from within / divide and conquer etc.

[S-Works]

It is not the ATP holders it is the European Cockpit Association. The UK guys it seems on the whole are behind the IMCR, it is their union BALPA that needs to put pressure on all of the other unions that form the ECA to agree.

BALPA running a campaign would be a good start.

[IO540]

As far as EASA is concerned, the UK is solidly behind the IMC Rating - either retaining it just in the UK or grandfathering its privileges into something pan-European.

The problem is some other European countries, notably France and Germany. Over there, objections have come from airline pilots, their unions, and their national CAAs. However, none of these objections are based on any evidence whatsoever - they are merely adopting a "there must be no flight in IMC without an IR" position.

Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.

The task ahead is to come up with good safety data which can be used to convince these people, and IMHO this isn't going to be too hard because the evidence is clear: there have been thousands of IMCR holders flying on it for decades and there is very close to zero evidence of any of them having accidents attributable to the exercise of the privilege. On the scale of statistics, it doesn't get much better than this.

Which is not to say it will be easy because blind prejudice is hard to work with.

[FullyFlapped]

Quote:
bose-x, that's not quite as I saw it!

not how Bose x saw it either!!!



I think Bose-X was simply doing us the favour of reposting elements of an open letter taken from "the other place" - not suggesting it was his own report (unless of course is is the editor of AOPA mag, something of which I have no knowledge).

Agree with Beagle : let's concentrate on the issues, not on each other, eh ?

[S-Works]

Thanks FF, at least you took the time to read the post rather than just looking for a childish reason to fight with me.

As far as IO's view is concerned, it is exactly what I have been saying all along, the UK is behind the IMC the rest of Europe is not and it is they that needs to be convinced. I have seen nothing yet put forward that if playing devils advocate I was European would convince me.

As I have said before the safety case is an interesting angle, how do you make it stack up when the rest of Europe (with the exception of the French) seem to get on quite fine without it. Our weather is not unique, look at Ireland and and the western coast of Europe.

I really do think that the plan of action should be to get a permanent difference filed and leave it at that.

[FullyFlapped]

Do figures exist which show a marked disparity in IMC-related accident rates between IMCr holders and non-holders ? Or how about between holders and the non-IR PPL population in Europe ?

[rustle]

...they are merely adopting a "there must be no flight in IMC without an IR" position.

Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.

This view is different from your beloved FAA view in what way?
[This isn't an excuse to tell everyone how great the FAA IR is, it is a genuine question about the difference in views between France/Germany and the US...]

[IO540]

It's obviously not a genuine Q rustle but I will answer it anyway.

The context is completely different.

The FAA IR is much more achievable than the JAA IR.

But then if Europe did not have its stupidly gold plated IR, increasingly gold plated over the past decades, and had improved the utility of GA with things like GPS approaches as soon as these became so obviously proven elsewhere, especially ones without on-field ATC, the present mess would not be such a mess.

Policymaking should be evidence based. There is ample evidence the IMCR is working well and has done so for decades. There is NO evidence against it.

A separate approach is to dump the IMCR and push for a "reduced IR". This is favoured by many - mostly Euro IR holders who got their IR many years ago - and is an objectively reasonable view. Unfortunately, the politics of that are just as hard, and additionally if this came about in any form that is actually likely in Europe (i.e. still a substantial ground school increment over the FAA version) we would not have the uptake which the IMCR has, not by a very long way.

The best solution for the UK is to work out some sort of UK-only exemption. I don't think it is impossible. But there isn't a formal mechanism for "filing a difference to EASA".

[rustle]

It's obviously not a genuine Q rustle but I will answer it anyway.

The context is completely different.

Actually it was a genuine question: Just because the answer is difficult doesn't make the question invalid. ;)

I support most of the various initiatives to maintain the IMC rating, but I don't think sidestepping questions about posts on here helps: If you're going to write things like
...they are merely adopting a "there must be no flight in IMC without an IR" position.

Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.

then you should be able to defend that posting when asked how that squares with the exact-same FAA view without resort to dismissing the question or telling us about an FAA rating that is irrelevant to the discussion.

[Islander2]

rustle:

The question you've posed to IO540 is a very, very good one, and its answer may well be a pointer to how this IMCR issue pans out.

So, perhaps you would like to advise us as to how the various UK GA representatives should best address the question!

To do so impressively would remove any lingering doubts that many on here may have as to your actual feelings (such as "I've got an IR so I couldn't give a stuff"!).

There's value in posing the difficult questions, no doubt.

But providing credible answers is what really counts. Can you?

[IO540]

The comparison with the USA, with its very different aviation scene, and its IFR privileges which are well integrated into its culture at all levels from low end GA to ATP level and whose achievability or syllabus are practically never even discussed let alone questioned anywhere on the vast U.S. aviation scene, makes for a funny and apparently provocative one-liner question on Pprune (and which really should thus have been posted on Flyer instead) but it doesn't help to work out a way to convince a number of traditional European aviation professionals that the skill set required to fly in IMC is nothing like the gold standard which they have spent their lives guarding.

A lot of it is down to personal experience. The people who object to any form of reduced-content IR (let's forget what one should call it for now) tend to be people who don't actually fly GA IFR. And many don't fly at all.

Even on pprune, it's dead easy to spot those who don't fly, from the stuff they write (or, more accurately, don't write).

The same is probably true for airline pilot bodies and airline pilot unions. There may be some active pilots among them but there are a couple of reasons why these people will have little or no GA IFR experience.

Firstly, if an ATP does fly for leisure, the last kind of flying he will be doing will be IFR. Ask any syndicate / timeshare setup how many serving ATPs they have as members. Most ATPs are a bit sick of IFR. For leisure, they fly rag and tube types. 100.000% VFR and on CAVOK days.

Secondly, GA of any sort and particularly IFR GA, is pretty thin in most of Europe. The UK is busy, Germany less so, France a lot less so, and the rest of Europe has relatively hardly any activity. By the time you get down to Greece you are looking at (of the order of) 200 GA planes - about 1% of the UK fleet.

This is why, as I have written many times, if you fly from say UK to Croatia, you might see 10 planes on a short leg in the UK but by the time you are in France the airspace is empty and then it gets even more empty. By the time you reach the Alps there is almost nobody "GA" on the radio. There are probably a few thousand IFR diehards zooming around Europe but even if each of them did 200hrs/year you would rarely meet one. Getting the full IR has been just too hard for too long.

So, taking Europe as a whole, there is going to be very very very little experience of GA touring among the people engaged in aviation professionally.

So it's no wonder that they don't understand.

And remember this is the same problem for both the "Euro IMC" and any reduced-content IR. Both of these initiatives are well stuck as a result. I wouldn't like to guess which is more stuck. Obviously the degree to which the IR is stuck depends on how much of the gold plating you want to take off - a recent 25% strip-off took ages and still got stuck. A "Euro IMC" is well stuck at the very start because it goes to the heart of the matter right away.

One could have a fun strategy debate which of the two is best worked on to un-stick it, but one thing is certain:

A "Euro IMC" would get picked up by a large % of pilots around Europe. Anecdotal evidence suggests the French and German PPLs would absolutely love it; especially German (and German-speaking) ones who do a lot more touring than the French. Whereas a "reduced IR", say 50% reduced ground school, would still be starting as an "IR", be taught by the professional schools, be examined by the professional pilot examiners, be fully ICAO and require the full JAA medical, and is never going to have much of a take-up. The yardstick for the likely take-up of any plausibly chopped-down IR would be the FAA IR takeup in Europe - at a guess, looking at IFR tourer sales, ~ 100 per year. The UK-alone historical IMCR takeup is 3x that!! The FAA IR takeup is of the order of 10x of the JAA IR takeup but that doesn't mean much because the JAA takeup is so close to zero (single digits/year in the UK, once you exclude the ATP pipeline crowd).

I don't know the answer. EASA does want to push an "IMC privilege" for PPLs and has done from day 1, more or less. If they didn't, you could forget it and an IR would be the only game in town.

It's all politics, so it's quite possible that the pressure to accept a low level IMC privilege (note: the name "IMC Rating" is a bit of a dirty word in Euro regulatory circles, alongside "FAA") may in fact ease in a substantially different IR.

Australia has an IMC privilege, done as modules. The 1st one gives you IMC enroute only (SRA is the only non-mayday IMC landing option). The next one gives you approaches, or something like that. Eventually you can reach an ICAO IR. This is a good way forward - so long as the VFR-only GA lobby don't screw it up again.

The future will be interesting.

[S-Works]

I have what I hope is a credible answer. The UK files a difference and leaves it at that. We don't try and get the IMC extended to Europe, we don't try and turn it into a mini/poor mans IR. We just leave it alone.

Credible enough?

[IO540]

The UK files a difference

under which EC article?

[Fuji Abound]

It should not be forgotten that it was widely reported by a few that:

the IMC rating was dead,

there would be no grace years,

it could have no place in EASA FCL

a national exception could not be filed

their would be no wider adoption of the rating

the lack of support from the rest of Europe would be insurmountable

None of these reports have yet proven correct.

That suggests to me that the campaign at www.ukimc.org has been useful together with the work done by those representative bodies in favour of retaining the IMC rating.

The support for the campaign has been over whelming.

I am in no doubt from the testimonies and comments we have received the vast majority of us are convinced of the importance of retaining the rating.

Over the coming weeks there will be more evidence to support the retention of the IMC rating. I believe that the evidence will be persuasive that there is a case for its wider adoption throughout Europe.

It is clear that the CAA support the rating.

It is clear that the statistical evidence presented at the press briefing would leave very few to doubt the proven safety record of the rating.

It is understandable that because many in Europe have no experience of the rating, they must rely on us demonstrate the ratings proven record in the UK

It is now for all the representative bodies, and for all of us, to rise to the challenge of ensuring the case is stated because I am in no doubt the evidence will ultimately prevail.

Please support the campaign, register your support at www.ukimc.org, and let us know if you are willing to lend your expertise to the campaign.

I believe it should be restated how this issue has progressed lest we fail to appreciate what has laready been achieved.

That said we believe we have a very good case for its retention in the UK.

I believe in what EASA are seeking to achieve. I am not going to be so disingenuous as to suggest that whats good enough for us is not good enough for the rest of Europe. We totally believe in the case we have, it is up to us to sell it to Europe.

I find it interesting that when I talk to pilots from Europe and to their organisations their intial reaction is exactly as would be expected. However, take time to explain how the IMC rating works, how pilots in the UK use the rating and set out the safety evidence that has already been well recited and they want what we have!

It is up to us to take the message to the rest of Europe - I think we will be pleasantly surprised by their reaction if we make a good job of it rather than bickering between ourselves.

[derekf]

IO540 - you asked "under what article should the difference be filed".

Article 10/5 - equivalent safety case - as suggested by Eric Sivel in your writeup.

[Islander2]

bose-x said:
I have what I hope is a credible answer. The UK files a difference and leaves it at that. We don't try and get the IMC extended to Europe, we don't try and turn it into a mini/poor mans IR. We just leave it alone.

Credible enough?If it were a long-term sustainable position, I for one would say that would be a very creditable result, albeit second best to a European-wide equivalent. But...

1. AOPA's notes of the meeting suggest that this solution is also subject to approval by people that are against the rating and is therefore problematic; and

2. it is no more a credible answer (or, for that matter, any answer) to the question rustle posed IO540 than was IO540's ... and rustle said that his was an unhelpful sidestepping of the question (I'm sure he'll be along in a minute to say the same to you ;)).

[Fuji Abound]

To reiterate my earlier comment it is clear to me we are convinced of the case for the IMC rating. The CAA are convinced. EASA would seem persuaded. BALPA support the rating.

Are we that disingenuous to our fellow pilots in Europe as to not at least seek to convince them of the merit of our case?

Do we truly believe that they are against the rating for the reasons regurgitated on here by a few?

Or might it be because we have not taken the trouble to properly present the case and the evidence?

After all we now have at least four years in which to do so!!

(Edited to add in so far as Rustle's question is concerned, and I am NOT making this comment to be argumentative, I didnt understand the question, so for those that did perhaps you could spell it out if it has not now been answered).

[bigbloke]

I notice that the http://www.ukimc.org/news.html has been updated and now includes a very comprehensive write up from yesterday's CAA / EASA press briefing.:ok:

[IO540]

IO540 - you asked "under what article should the difference be filed".

Article 10/5 - equivalent safety case

That is a misunderstanding, bose-x. Article 10.5 provides for a delay only. The matter then goes back to the commitology (sp?) committee and it can again be defeated by the majority according to the population-weighted votes.

10.5 isn't like a difference to ICAO which is permanent.

[FullyFlapped]

At the risk of opening another large can of worms - and I'm reeeeeeally not trying to, honest ! - what is the latest EASA position on N-Reg "airplanes" and the FAA IR ?

Has anything of interest been said anywhere lately ?

[S-Works]

Quote:
IO540 - you asked "under what article should the difference be filed".

Article 10/5 - equivalent safety case
That is a misunderstanding, bose-x. Article 10.5 provides for a delay only. The matter then goes back to the commitology (sp?) committee and it can again be defeated by the majority according to the population-weighted votes.

10.5 isn't like a difference to ICAO which is permanent.


Nothing is permanent. But it gives a better solution than trying to sell a rating to the Europeans at this moment in time.

[Islander2]

Nothing is permanent. But it gives a better solution than trying to sell a rating to the Europeans at this moment in time.
bose-x:

The meeting report you posted makes it clear that EASA see the Art 10.5 'equivalent safety case' route as a last resort for the UK, to be tried at the end of the proposed 4-year transition period.

If it is your position (and AOPA's) that UK GA should not try to sell an IMCR to the Europeans and should opt for the Art 10.5 route, could you please clarify what you (and AOPA) are proposing to do during the 4-year transition period?

[soay]

could you please clarify what you (and AOPA) are proposing to do during the 4-year transition period?
That's a good point. Who in AOPA is able to state their policy on this? If they were to poll their members, their position would carry more weight, and might be less negative than bose's appears to be.

[S-Works]

Tell you what Islander, YOU tell me what your case is for selling the IMCR to the Europeans and how you plan to get the majority vote that is needed for them to agree to file a difference with ICAO for a sub ICAO Instrument rating?

I am merely suggesting that if the IMCR is so unique to UK weather or other special circumstances that we have it how are we supposed to sell it to other countries that don't share our unique situation.

Therefore it would makes sense to just try and maintain the status quo?"

AOPA have already tried to get the IMCR taken Europe wide on the back of the RPL. This was lost and the vote was to keep the RPL as day VFR initially. At the moment I do not see a route for adding a non ICAO rating to the new EASA ICAO license but would welcome any suggestions.

I have extended the offer to Fuji to talk to me in private about an AOPA/IMCR campaign initiative. I will not carry out AOPA business on these forums, as I have said before my opinions here are my own.

I await his response.

[IO540]

It was made absolutely clear at the meeting that article 10.5 is the option to be used at the end of the 4 year period, to achieve an additional extension.

There is no mechanism for "filing a difference" at an early stage. This is not ICAO.

Regarding AOPA, why doesn't Martin Robinson come online (they have their own forum; not that many people go there) and tell everybody what the position is, instead of various versions of it coming out on the forums, often in the form of aggressive postings.

I actually think AOPA do support the IMCR (cannot think of any reason why not - it's good for pilots and it's good for their corporate membership revenue and the CAA backs it) but the politics of the whole thing are very convoluted.

As has been written elsewhere, EASA are revisiting the whole business of private IFR privileges anyway, so the MDM032 VFR-only-LAPL screw-up is not (currently) the end of the world.

I am merely suggesting that if the IMCR is so unique to UK weather or other special circumstances that we have it how are we supposed to sell it to other countries that don't share our unique situation

That is in fact not the case. UK IMC is just like any other IMC. We get more really really crappy weather here than say central Europe but few private pilots fly in OVC002 anyway. The sort of IMC which is flyable without CAT2 occurs everywhere.

The UK has more class G than most, but France has loads of Class E which is just as good.

[S-Works]

Thank you IO, you have just made my point. The IMCR does not exist because the UK has unique weather.......

So you either have to get a majority vote in Europe to either get the IMC on the LAPL which makes sense, sub ICAO licence with a sub ICAO rating or get a majority vote to have EASA file a sub ICAO Instrument rating with ICAO.

I am just asking how this is planned to be done. We now have a 4 year breathing space to come up with a plan.

I have no idea how this will be achieved, so open to answers from the floor.

[Islander2]

Tell you what Islander, YOU tell me what your case is for selling the IMCR to the Europeans and how you plan to get the majority vote that is needed for them to agree to file a difference with ICAO for a sub ICAO Instrument rating?bose, that's hardly a reasonable response to a request to understand AOPA's position on this vital issue. You are, after all, AOPA's representative for IMC/IFR.

I would not purport to have any insight to the best strategy. What I would say, however, is that the case of selling to the Europeans isn't conceptually a great deal different to the uphill struggle that the CAA and AOPA had against similar resistance in the UK during the 1960s. Yes, there are airspace differences, but that's a resolvable problem. BEagle has proposed one sensible and pragmatic way forward and, as you know, I've suggested an alternative to PPL/IR Europe.

In one sense it should be easier. For the UK IMCR, the CAA and AOPA were arguing, without any data to back up their case, against entrenched attitudes claiming it would be unsafe. Now we have 38 years of data that solidly support the brave position those two organisations took!

[IO540]

A few random points:

EASA's plan is to file ICAO differences on the LAPL and any IMC privileges which appear either on the LAPL or on some other license. This means these things would be usable outside the EU. Loads of countries have filed differences to ICAO. The result is not "sub ICAO"; it is still 100% ICAO compliant. The majority of airliners landing at Heathrow as we speak are flown by pilots flying on some kind of "ICAO difference filed" piece of paper. This is how the world runs. They could not have got 195 (?) countries, including all the dictators and all the cannibals, to sign up to it otherwise.

The original IMCR introduction was not some great brave act against massive airline pilot opposition. Prior to it (c. 1969) a plain PPL could fly in IMC. Some got killed, and the rules were tightened, and after a few years we got more or less what we have today. It was a different era when people were a lot more bold and not hiding behind all the health & safety b01locks we have today. The result has been spectacularly successful, in terms of how many have got killed while actually exercising the IMCR privileges. See the slides at www.ukimc.org (http://www.ukimc.org) under Latest News.

The strategy is not going to be worked out on pprune!!! Nor should it be. So there is no point in having some kind of aggressive ping-pong here about it.

[S-Works]

Islander I think I made it clear in my post the situation. We are in new territory and there are no answers. If you have a solution than I am more than willing to listen to it. If you don't then I suggest you hold back on lambasting others.

I have made the offer to Fuji to contact me directly as the AOPA rep to develop strategy. As IO points out PPrune is not the place for it.

I await his contact, he now has my private details.

[Wrong Stuff]

I don't know why you're getting upset bose-x. Islander's really just tried to play devils advocate with his recent posts and make the people who are working on campaigns to save the rating actually think about why they want to save it and what it is going to be used for.

[S-Works]

Wrongstuff, I have no idea whay you think I am getting upset, my last post was quite clear, we are in new territory and I have no answers. I have offered Fuji assistance. I await his email.

[BEagle]

I really do wish that those who claim to represent major GA organisations would moderate the tone of their posts. Rude, intemperate and vitriolic outbursts merely cast doubt on the worth of the organisations with whom the poster claims to be associated.

I've asked before that everyone involved in the current UK IMCR/EASA Class 2 IR issue would refrain from internecine wrangling and concentrate on corporate synergy.

So please take your handbags elsewhere and stop diverting attention from the core issues.

Thanks.

[BroomstickPilot]

OK Bose-X,

Here's the germ of an idea. It is only one little idea and I feel we need a lot more ideas before we have enough. But here's a start.

I feel we need some means of enabling pilots in other EU countries to get some idea what having an IMCR can do for your flying, so that they will want one too.

Clearly, we cannot bring them all over here. But what we might do is to produce a film/DVD of what it is like to fly in the UK using the skills of the IMCR. This could be made available to flying clubs in other countries through International AOPA to play at club nights etc. It could also be made available to individuals provided the price is reasonable.

Even if the commentary is only in English, it would be understood by enough pilots in the Netherlands, Belgium, Denmark and Norway. If it could also be made available in French, then clubs in France, Belgium and Switzerland would be able to use it. Add in German and it would be usable in Germany, Austria, Switzerland.

Well, there's a start.

C'mon, who's next?

Broomstick.

[Fuji Abound]

Broomstickpilot

A good idea. It will take some work.

You will see there is another post running asking for help with langauge - worth a look.

We at the www.ukimc.org are intending to widen the debate into Europe and make a start by engaging other countries by "posting" our site in a number of languages and working with their bulletin boards, GA magazines and others to explain why we believe the IMC rating is so useful.

I understand that English is a common and universal language of pilots, however if it is not your first language some of the subtetly and detail is easily lost and it is up to us to make the effort.

It is the germ of an idea, but I am amazed at the support we have had and the people who have offered to help - thank you.

We hope to get it off the ground soon!!

[BRL]

I have just deleted and edited a few posts from the last day or two.

There is a time and a place for bitching and sniping but not here ok.
as mentioned previously, Beagle makes a good point in his last post, I suggest people re read what he has written.

llanfairpg You have contributed nothing to this thread, just wound a few people up hence the deletion of some posts. It is not big and it is not clever hence the forthcoming ban.....

[soay]

I have just deleted and edited a few posts from the last day or two.
Good idea. There's a pettily offensive one here (http://www.pprune.org/forums/showthread.php?t=308617&page=3#47) that you might like to prune, while you're at it. It doesn't even make sense.

[S-Works]

And not a bad one at that. What you need to be very carefull of is making it out to be a mini IR. Push the benefits of the IMC in its basic form, the ability to climb over an overcast and do a let down in a situation that could have ended up in a CFIT.



OK Bose-X,

Here's the germ of an idea. It is only one little idea and I feel we need a lot more ideas before we have enough. But here's a start.

I feel we need some means of enabling pilots in other EU countries to get some idea what having an IMCR can do for your flying, so that they will want one too.

Clearly, we cannot bring them all over here. But what we might do is to produce a film/DVD of what it is like to fly in the UK using the skills of the IMCR. This could be made available to flying clubs in other countries through International AOPA to play at club nights etc. It could also be made available to individuals provided the price is reasonable.

Even if the commentary is only in English, it would be understood by enough pilots in the Netherlands, Belgium, Denmark and Norway. If it could also be made available in French, then clubs in France, Belgium and Switzerland would be able to use it. Add in German and it would be usable in Germany, Austria, Switzerland.

Well, there's a start.

C'mon, who's next?

Broomstick.

[BEagle]

BRL, thank you for your PPRudeNt housekeeping!

Regarding the AOPA 'position', I have just been chatting to the CEO who was on his way back from Brussels. Having had a very productive week with EASA, he tells me. But at present AOPA is in the information-gathering phase over the UK/EU IMCR/Class 2 IR, which is essential before the forthcoming strategy is formulated. Views of all the AOPA committees will be studied, then the overarching position announced.

There is no one, specific 'AOPA IFR/IMC representative', nor will there be; the Association will be working with its membership and with others to formulate the best way ahead over this whole issue. In particular with those at the CAA who are best placed to help.

Lastly, I again ask that anyone associated with a major GA group should adopt a temperate, constructive approach. If necessary I will ask the moderator to intercede; I will not name names as I'm sure you know who you are.

[S-Works]

Oooh! Thanks uncle mike.

[BEagle]

Now that the FCL.008 NPA is about to be released (23 Sep is the latest date....20 months after it should have been) and there's a 1 day 'workshop' being held at EASA on 30 Sep, perhaps it's timely to reflect on some of EASA's assurances about the IMCR made over the last 3½ years:

22 Jan 2008, CAA Kingsway: Concerning the UK IMCR, Eric Sivel stated to the audience, including Ben Alcott from the CAA, that EASA would “Find a European solution before the end of the (JAA to EASA) transition period”.

2 Dec 2009, EASA Köln: Eric Sivel stated to AOPA and others that “If FCL.008 does not find a solution to the UK IMCR, then it will have failed to meet its objectives”.

The European Commission's Air Transport Directorate also gave assurance to the European Parliament that "EASA’s general objective is to transfer the UK–specific IMC rating into the future European system."

It will be interesting to see whether any of these facts have been taken into account in EASA's forthcoming NPA......:hmm:

Going by the original timescale, it will take about 14 months between the NPA appearing and an EC decision. Which means that it'll be Nov 2012 at the earliest before the final decision will have been made....:rolleyes:

[Genghis the Engineer]

Presumably that means that PPL's who haven't yet done the IMCR may have another years grace to try and get it done?

Presumably......

G

[Pace]

Beagle

They also stated the extension till 2014 (now we believe 2016) was soley to get a bi lateral agreement on FCL with the FAA. Something they would work hard to achieve.
Do we believe that too or have we all been taken for one big ride.
The solution will not be with an IMCR that I am sure of. It maybe with an FAA style EASA PPL IR especially if the French and a few other larger countries force EASAs hand by bringing out their own regardless.

Pace

[S-Works]

As I said right at the start of this. Whilst I hope the outcome is sucessful it is my belief this has always been a done deal and all the promises have been politicians at play keepingt he natives quiet while they carry on as they please.

Exactly the same as panned out with the FAA licencing issue.

I wonder when people will realise that politicians are just lying, cheating, fiddling and self serving. It is naive to think that these people think they are there to serve us.

[Gertrude the Wombat]

I wonder when people will realise that politicians are just lying, cheating, fiddling and self serving. It is naive to think that these people think they are there to serve us.
That is not an accurate description of most of the politicians I know, and I claim that it is not an accurate description of me.

If you want politicians to take you seriously you are going about it the wrong way by publishing that sort of statement. Guess how much notice I would take of anything said by one of my constituents after they'd described me in such a way?

[BEagle]

Quite so, Gertrude! In the campaign to resist EASA's attempts to shaft us unmercifully, it has been the timely help of MEPs which has forced comment from the Commission.

One of the EASA €urocrats had the front to state that our political lobbying had been 'unhelpful' with regard to their licensing proposals. Well, tough titty, mein junger Freund, but the last of your countrymen who found democracy inconvenient, a certain ex-corporal with a penchant for silly face fungus, finally met his end on 30 Apr 1945.

The European Commission and EASA should be given a much tougher time by the European Parliament and should told to stop re-inventing the wheel or adding new rules for which there is simply no valid need!

Incidentally, it simply wouldn't be possible for an 'FAA' type of IR to be taken into part-FCL, because unlike the FAA PPL/IR, part-FCL calls for regular retesting. None of this revalidating by time/approaches, it would mean retesting with a suitably qualified examiner at periodic intervals. As is the case with the current UK IMCR, of course.

[S-Works]

That is not an accurate description of most of the politicians I know, and I claim that it is not an accurate description of me.

You are no doubt going to be granted a sainthood.

However the politicians in jail and paying back huge amounts of our money have done little to credit your cause. Duck house anyone?

I am glad I am not one of your constituents, although only a few miles away I guess I have a lucky escape. Freedom if speech should allow me to say exactly what I think. Generalising about the overall political scene should not give you a right to withdraw your political services. Unless of course you are telling me you do not go into public off ice to serve the people, all the people, but just the ones you happen to agree with?

[Proteus9]

This seems to typify the attitudes of many civil servants in general be it Europe or MPs here. When people who make the rules either know very little about what they are involved with or worse, choose not to follow them and expect to get away with it is extremely annoying. Watching MPs on tv say that they can't be expected to make a note of what they spend their time doing, or even worse having to pay expenses out of their own pocket then claim them back. When it is widely accepted as normal practice in the private sector.
Europe is the same, I find it amazing that the auditors have refused to sign off their accounts every year since they were brought in, yet very few people seem to be bothered by this.

There is no doubt that there are some good politicians who do not take this piss with house flipping, capital gains tax dodges and expenses fiddling. However, the actions that were shown to be widespread have brought disgrace to the house, and it needs more than some lip service to mend the damage done.

The only amusing part of it right now is watching various politicians play the music whilst the Euro ship is sinking.

I'm contemplating doing my IMC rating now, but it still seems like a gamble. I've heard the argument that if you have it you will be given grandfather rights. However, it appears that the NPPL rights to fly C of A are being removed completely so presumably the same could happen with the IMC. It would be great if there could be some clarity about it, as it is a reasonable expense to undergo (even if nothing of the level of the IR). Yet with the deadline looming there seems to be not much more than: Change is coming, we are not sure what it is, but you must comply with it.

[Gertrude the Wombat]

However the politicians in jail and paying back huge amounts of our money have done little to credit your cause. Duck house anyone?

Yes, that's about half a dozen corrupt ones out of many thousands. I wonder how many professions do significantly better than that?
Freedom if speech should allow me to say exactly what I think.
Within the law. And there are lots of laws about what you can and cannot say. Accusing people falsely of being criminals is one of the things that people can, and sometimes do, take legal exception to. Once upon a time a false accusation of corruption could have led to a dual, not just a libel action.

[Pace]

Gertrude

Politicians honest? It depends on what you call honest.
Look at whats happening in the USA? No one wants to do anything which will harm their own side so they do nothing until after the elections?
Best interest of the USA?
How did 4 MEPs who were committed to opposing the N reg changes change their minds and allow the whole lot through? Standing up to what they believe in or shady deals and promises behind closed doors?
Sadly its all about personal agendas and you rub my back I rub yours.

Pace

[S-Works]

Gertrude, I am well aware of what the law allows me to say. And trust me there is nothing stopping me saying what I think about politicians. If may hurt your feelings but you have all made a rod for your own back. It's not a few rotten apples, it's mass scale abuse of the system and therefore abuse of us they are meant to serve.

However if you feel slighted, I am happy to meet you on the common at Dawn with dualing pistols in hand. Will you be bringing your own or expensing them? :p

[Proteus9]

A half dozen out of many thousands.

Was it not that 350 out of 650 MPs were ordered to pay back expenses? This hardly indicates a few nasty people amongst the whiter than white majority.

Court refuses trial by combat - Telegraph (http://www.telegraph.co.uk/news/uknews/1416262/Court-refuses-trial-by-combat.html)

[thing]

Gertrude I don't think it's a case of people being personally angry towards politicians, I just think that people have washed their hands of them. They are finished.

An example off the top of my head: Francis Maude, we won't even mention his expense 'peculiarities', is a proponent of Dave's Big Society run by volunteers. When asked in an interview what voluntary work he did his reply was something along the lines of 'None'. He was also vocal in his decrying of banks who invested in sub prime whilst being a director of a company which did just that.

It doesn't even register a 'Oooh the bounder' anymore, people expect politicians to be duplicitous and to be honest they are hardly let down are they?

[Gertrude the Wombat]

When asked in an interview what voluntary work he did his reply was something along the lines of 'None'.
Well, I can tell you what voluntary[#] work I do.

I've taken a chunk of today off paid work, with more to come tomorrow (around £150 worth), and three full days next week (which is £££lots, plus there will be expenses of several hundred pounds out of my own pocket), to do unpaid work for the people who elected me. I'm typing this whilst having a coffee break in the middle of reading hundreds of pages of documents for tomorrow's meetings, which I won't actually get finished by the time I feel like going to bed at midnight.

What voluntary work have you done today, and how much did it cost you? (Not suggesting you didn't, just asking like.)

[#] Well, you could argue that my current position is not entirely voluntary in that I got my arm severely twisted to accept it.

[stickandrudderman]

Being a politician is in essence a noble thing to do. The trouble is that public perception is that very few MPs understand that in order to be credited with being noble all they have to do is to ensure that that which they do is a direct reflection of the people's wishes. As far as I can tell the only truly nobleman in any form of office in this country is the Mayor of Doncaster.
The beginning of the end for Political Correctness: the counter-revolution has begun in Doncaster – Telegraph Blogs (http://blogs.telegraph.co.uk/news/geraldwarner/100008053/the-beginning-of-the-end-for-political-correctness-the-counter-revolution-has-begun-in-doncaster/)
:D

[thing]

What voluntary work have you done today, and how much did it cost you? (Not suggesting you didn't, just asking like.)I do voluntary work most Saturday mornings, not saying what it is 'cos this isn't a trumpet blowing session. However I don't say that everyone should do voluntary work and then do none myself. Nor should anyone be pressurised into doing it.

I know how much time and effort politicos put in as my old man was a local politician for decades (in fact he was Eric Illsley's agent...:ooh:) and the time and dedication he gave to it far exceeded the renumeration he got from it. However for each one like him there would be another who was in it purely for their own interest, or if not purely for their own interest then it wouldn't be far from the front of their mind. Some of the stories he's told me would make your hair curl.

[IO540]

Being a politician is in essence a noble thing to do.

I think that has been true throughout history, when you needed copious personal wealth to give you the spare time and independence to participate in top level politics, but it is clearly much less true nowadays, with so many politicians being driven by chips on their shoulders, a desire for fame, or (in the case of Brussels) a blatent gravy train ride and a desire to be associated with some great treaty.

Local politicans vary but my experience of them (Sussex) is they are mostly inept, and a few are blatently corrupt.

[JOE-FBS]

Completely off-topic as we now are, any reader of Private Eye will tell you that Doncaster (my home town although I left 27 years ago) has for many years been dreadfully corrupt.

To me, that new mayor sounds typical of the sexist, racist locals that I meet if I venture out when visiting family up there.

[IO540]

Private Eye has had its ups and downs but it has never had it so good with top notch cynical material to take apart as today.

Not since the James Goldsmith days, but they did labour those a little at times...

[Duckeggblue]

So.... is it only me who is confused :confused:

I understood that we had until April to get -or, in my case, revalidate my IMC.

I may then (at an undetermined point in time) be assigned some form of diluted European Instrument Rating - which may (or may not!) allow me to fly both in the UK and outside the UK in IMC
- or some form of "Grandfather rights" over IMC privileges in the UK

Is this still correct, now incorrect or was never correct?
What is considered correct, or even likely, at this point - if anything?

[IO540]

I'd say that is 100% accurate :)

The only thing anybody can be sure about is that having a valid IMCR in April 2012 is a good idea.

[Pace]

I may then (at an undetermined point in time) be assigned some form of diluted European Instrument Rating NOT CORRECT- which may (or may not!) allow me to fly both in the UK and outside the UK in IMC NOT CORRECT
- or some form of "Grandfather rights" over IMC privileges in the UK CORRECT

Is this still correct, now incorrect or was never correct?
What is considered correct, or even likely, at this point - if anything?

[Whopity]

It really demonstrates that EASA has nothing to do with Safety. Here we have a rating that has a track record indicating a safety benefit for a good many years. Is this part of the consideration? No. The issue is, can they make it fit into their bureaucratic rule book! Without the IMC, more pilots will die chancing their arm in marginal conditions, is that a consideration? No.

The FCL008 group are totally inept and their stupid en-route IR is as much use as a concrete parachute. Meanwhile, the French continue with their flanker of a non JAA, ICAO IR that will no doubt become an EASA IR on conversion.Is this still correct, now incorrect or was never correct?Its as good as a Politician's promise! An illusion, to make you think its correct when in reality it was never intended to be correct, so its probably incorrect.

[mm_flynn]

I would suggest everyone take a deep breath and stop slagging off ideas/proposals because they don't fit exactly with your view of the world ...
The NPA will come out in a little over a week and at that time we will be able read an actual proposal and come to a conclusion.

After we read the NPA, remember not everyone flys the same, try to be rational about the various options. If we get a set of proposals that keeps the IMCr community whole, allows a graceful way through for both private and commercial N-reg, makes a substantial improvement in the EASA IR process, and maybe introduces some intermediate level of IR that would be fantastic (but probably a dream).

To the extent that anyone winds up shafted vs existing privileges we should all express our outrage (even if our particular aspect of IFR ops is OK). However, we should do that in a constructive way rather than slag off other parts of the proposal. No matter what is in the NPA there will be interest groups opposed and providing ammunition to the arguments from GA is not very helpful.

[Duckeggblue]

Thanks for your thoughts.

The only thing anybody can be sure about is that having a valid IMCR in April 2012 is a good idea.

About right IO540 :ok:

I think most people are just trying to find out what is going on and it is frustrating being unable to find a source of accurate information.
It doesn't occur to most people that there may not actually be one!

It is what it is.
Slagging off politicians (or anybody!) won't change it .......

For what it's worth, regardless of the privileges I get to retain, the skills honed doing the IMCr training and the awareness gained of potentially hazardous situations will always be mine - regardless of how rusty the skills have become. For this alone, it was worth it.

[Pom pom]

Could someone please clarify if a proposed Annex II aircraft (when/if that happens) is the same as a Permit to Fly aircraft. If the former is simply a renaming by EASA of the latter, then presumably that means no IMC/international/night flights on the new Annex II. But, an article in October "Pi*ot" mag (about aerobatic ratings) suggests otherwise. I understand IF equipment requirements re flight in IMC, but if an aircraft met these but was Annex II (thinking Bulldog/Chipmunk) would the aforementioned flights be prohibited?

:confused::confused::confused:

[BEagle]

Permit to Fly aircraft are only one group of 'Annex II' aircraft.

Chipmunk / Bulldog / Harvard / Tiger Moth / Piper Tri-Pacer and others are 'non-EASA' types which also fall into the 'Annex II' aircraft category.

Even after the nonsense of €urocracy is inflicted upon us, you will still be able to train for the UK IMC Rating on appropriate Annex II aircraft (such as the Chipmunk / Bulldog / Tri-Pacer etc.) and include it in a United Kingdom Pilot Licence. As is the case today, you will only have IMCR privileges in UK airspace.

If I was looking for a private aircraft to own and potter about in, it'd be a nice Piper Tri-Pacer or Caribbean - and to hell with EASA!

[Pom pom]

That was my understanding too until someone at my club told me I was incorrect. Ultimately we may all end up being incorrect with our speculations/interpretations, so|I'll keep me mouth shut an' me ears open 'til it's sorted. Thanks for your confirmation Beagle. :ok:

[Genghis the Engineer]

Annex II aircraft are aircraft not administered by EASA.

This includes warbirds, small run aircraft of national significance, microlights, research and experimental aircraft, and homebuilts.

The majority of those are PtF, but not all.

If Concorde was still flying that would meet the definition of Annex II, as does "Metman" - the atmospheric research BAe-146 (G-LUXE), both are quite definitely on Cs of A.

G