AOPA and IAOPA clarrify their position on the IR and IMCr

[Fuji Abound]

It is well worth reading these articles which help to set out IAOPA's and AOPA's position on these very important issues.


http://www.iaopa.eu/mediaServlet/storage/gamag/oct09/p5-20.pdf

[englishal]

I never really understood IAOPA. As I am a member of AOPA US, does this mean I am a member of IAOPA?

[S-Works]

AOPA is a franchised organisation in Europe with each country having its own AOPA organisation licenced to use the AOPA name.

IAOPA is an overarching organisation that uses experts from within the national AOPA's to act as a single voice rather than trying to have one from each branch.

[IO540]

From that PDF:

As forecast in the August issue of this
magazine, it’s back to ICAO and the JARs
unless there’s a pressing safety case against
them. Third country operations, which
promises to be a battlefield, goes to the back of
the queue.

Sounds good to me :ok:

[sternone]

Good news.

[IO540]

Indeed - but never count your chickens until they hatched. That AOPA newsletter has a great article about how the UK CAA managed to avoid "excessive loss of work to EASA" and how this included collaboration with other European CAAs who were facing the same threat.

The EU organisations are staffed with very bright people (with the money they pay, they can afford the brightest - if not the most customer-motivated) and will be very skilled players in work creation.

[Mike Cross]

I never really understood IAOPA. As I am a member of AOPA US, does this mean I am a member of IAOPA?

In this case it's IAOPA Europe, which is the European AOPA's working together.

Being a member of AOPA US does diddly squat for anything in Europe. Bizarrely some people think it does.

IAOPA and IAOPA Europe are there to represent national AOPA's in the case of IAOPA Europe to the EU and its aviation organisations like EASA, in the case of IAOPA to ICAO, on which it has a representative.

It's a bit like the BGA where you are a member of a Gliding CLub, which is affilliated to the BGA. That doesn't make you a member of BGA.

[FREDAcheck]

Dr Michael Erb of AOPA Germany, attempted to get the group to develop a follow-up to the IMC rating when it met in Cologne on May 28th, but FCL-008 refused. Instead, it has flown off on a baffling tangent by introducing the idea of an En-Route Instrument Qualification proposed by Jim Thorpe of Europe Air Sports which would allow a pilot to fly in IMC on airways, but would not allow him to land other than in full VFR conditions.
Glad to see AOPA share the views of many of us about Jim Thorpe. I'm sure he's done great things for PPL/IR, but his proposals risk doing enormous damage to the interests of a much greater number of flyers with IMCR. As AOPA says, it's unlikely the airlines would accept his en-route IR, so his proposal (if pursued) will merely see IMCR buried. A cynical person might wonder if Jim knows that.

[Fuji Abound]

I wonder what Jim Thorpe's mandate is?

Does he represent the interest of PPL/IR or does he represent himself? I assume the former unless he was co-opted as a self proclaimed expert.

If he represents PPL/IR is it the case that the membership supports his position and if they do how have they signified they do? If they dont they should instruct him accordingly.

I ask because I always find it very odd when it would seem someone is so out of tune with those they represent.

I think it is important that the associaiton with PPL/IR is clear (if it exists). Its very easy for such organisations to disassociate themselves from an individual who is there with their mandate. If PPL/IR agree with Jim's stance they should have the guts to say so and be damned (or not).

(Forgive me if PPL/IR and their members have / have not already proclaimed their support for Jim - I dont know the answer which is why I am asking)

[mm_flynn]

It is widely believed, still, that it [the IMC] is a ‘poor man’s instrument rating’ which allows access to controlled airspace and will clutter the ILSs of Europe with light singles
The more vociferous critics of FCL.008 seem to want to use the IMCr in exactly this way.

FCL.008 is a European working group, not a 'save the UK IMCr' group. That is AOPA UK's roll and the referenced document makes clear that AOPA UK is on the case to save the IMCr. However, it is pointless to put the IMCr on the agenda for Europe without some understanding of the reality of the airspace and regulation differences. It is equally silly to try to legislate a European rating that is then locally banned by all countries other than the UK! (unless of course it is a necessary fudge to save the IMCr - but at least it would be a conscious fudge rather than a waste of legislative time)

It is predominantly the UK that uses low level Class A to separate GAT and CAT activity. Most other countries allow these activities to co-exist in most/all airspace below FL195. As such, a Euro-IMCr constructed along the lines of the UK IMCr, would be exactly what the AOPA link says it wouldn't be. It would allow people access to pretty much every cubic meter of airspace outside Italy and the Paris TMA. It would be equally reasonable for the rest of Europe to insist the UK reclassify all Class A airways below FL195 as Class D/E.

[BEagle]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.

For example, you could legally scrape over the cliffs into Cardiff VFR below a low cloudbase, but you couldn't fly an ILS in IMC.

This was later amended, so that only Class A airways are now off-limits to IMC rating holders; SVFR is permitted in Class A CTRs, but not in airways.

AOPA's point is that it would be entirely up to national airspace authorities, not EASA, to decide whether an Intermediate IR could be used in whichever part of their airspace they see fit. As is currently the case in the UK for the IMC rating.

[FREDAcheck]

FCL.008 is a European working group, not a 'save the UK IMCr' group.
Maybe not in those words, but its Terms of Reference include:
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges

[englishal]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.
And this is where I believe the "...only outside controlled airspace" limitations for foreign IR holders came from.

In the past the IMC rating did not allow IFR "in controlled airspace" but airspace which is now class D was not defined as "controlled", with "controlled" referring to Class A only.

When airspace was re-classified, and JAR came about, the IMC rating was redefined to include "controlled airspace, class D and lower" however the definition for foreign IR holders was omitted, probably by accident. The reason I reckon it was a clerical error was because the CAA used to have on their website that "foreign IR holders can exercise the same privileges as an IMC rating holder". However because of an omission (i believe) in the ANO the "outside CAS" limitation was never updated for foreign IR holders, and as "Class D and below" is now referred to CAS, and not just class A, then this effectively banned them from any airports in class D airspace (IAW IFR).

I haven't looked for a while, but I believe an IMCr attached to a CAA licence could also still have this limitation somewhere in the wording.

[BEagle]

Nope, Schedule 8 clearly explains the restrictions which apply to both UK-lifetime PPLs / BCPLs and to JAR-FCL pilot licence holders who do not have IMC ratings included in their licences.

I don't know what applies to foreign licence holders; my understanding is that the FAA views the FAA PPL/IR as equivalent to the UK IMC rating in G-reg aeroplanes.

[IO540]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.

For example, you could legally scrape over the cliffs into Cardiff VFR below a low cloudbase, but you couldn't fly an ILS in IMC.

This was later amended, so that only Class A airways are now off-limits to IMC rating holders; SVFR is permitted in Class A CTRs, but not in airways.

I am reliably informed by someone who has been digging around this a lot longer than I have that the words "UK only" were also missing from the ANO, not many years ago, on the IMC Rating IFR privileges :)

The bizzare thing is that the CAA was free to put out an ICAO Difference on the IMCR. Had they done so, it woul dhave been valid worldwide except where the airspace owner objects.

my understanding is that the FAA views the FAA PPL/IR as equivalent to the UK IMC rating in G-reg aeroplanes.

Not heard that one anywhere. The FAA told me, in writing, that they regard the IMCR as equivalent to the FAA IR (within the limitations of the IMCR itself of course i.e. UK only, no Class A etc).

The privileges in a G-reg are up to the CAA, not the FAA. As regards how the CAA views the FAA IR, to the extent that for £70 or so an ICAO IR holder can buy himself an IMCR. In the case of the FAA IR he needs to be within his IPC (i.e. the CAA disregard the FAA rolling currency rule). He also needs a UK/JAA PPL or CPL, a UK medical, etc. It's not a terribly useful maneuver but a G-reg pilot gets IFR privileges for Class D, whereas with an FAA IR he would have them only in Class F-G (which is close to useless for going places).

[Fuji Abound]

I am reliably informed by someone who has been digging around this a lot longer than I have that the words "UK only" were also missing from the ANO, not many years ago, on the IMC Rating IFR privileges


Yes, but it is only within the grant of the national authority to allow IFR with a non ICAO rating regardless of the registration, notwithstanding that an FAA IR whilst an ICAO rating departs from the ICAO standard by a long list of differences as do many other IRs.

If DGAC were to tell you they accepted the IMCr for IFR ops then you would be good to go in the same way that if you are a non European national they will recognise your FAA IR in a G reg aircraft.

[IO540]

This is rather irrelevant but I don't see how the IMCR (no Class A) is sub-ICAO any more than any IR (with some other limitation say no commercial use and needs to have one's left goolie weighed every 6 months) is sub-ICAO.

If you take the IMCR and remove the fairly recently added "UK only" limitation, it is totally equivalent to a full IR - in any country in which Class A is either missing or not operationally relevant (i.e. all except UK and Italy, in Europe).

In terms of how the syllabus matches all-airspace full-IFR operational requirements (let's forget for now that the IR syllabus is woefully inadequate for real GA/IFR) the only really big bit missing from the IMCR is SIDs/STARs, and they require the amazing ability to ..... wait for it ..... READ the piece of paper with "STAR" in the top RH corner :)

It's all about the politics of professional pilot status in Europe, which for historical reasons has become closely attached to the IR. It should actually be attached to the ATPL (which is how it works in the USA) but Europe has structured the ATPL into a free gift to any fATPL pilot reaching 1500hrs with the MCC time etc. So, since the ATPL is basically a bogus thing over here for anybody with a RHS MCC job, they had to tie professional pilot status to something suitably elitist, and the IR is the only thing that's left. The CPL is a VFR-only exercise which "anybody" can pass, eventually, but by itself it is useless.

[BEagle]

Yes, the platinum-plated UK IR was once described to me by a CAA Examiner as "The last chance we have of weeding out someone who wouldn't be suitable for the airlines".....:eek:

Suitability for commercial employment should more reasonably be assessed as part of a commercial pilot licence test, whereas assessment of the applicant's ability to fly an aircraft by sole reference to instruments should be the sole function of an instrument rating test.

Neither is there any logical reason why an initial IR Skill Test must be conducted by a CAA Staff Examiner.

[IO540]

Neither is there any reason for the IR to be taught only at professional FTOs.

If you don't go for demonstrated competence, the whole thing is bogus.

"Industry interests" is what that bit is about.

And this prevents penetration of the GA market, because most pilots are not within "same day drive there and fly" distance of a pro FTO, so are looking at a residential deal.

Another very simple thing the FAA has got right (freelance instruction and freelance (FAA DPE) checkrides).

[bookworm]

Suitability for commercial employment should more reasonably be assessed as part of a commercial pilot licence test, whereas assessment of the applicant's ability to fly an aircraft by sole reference to instruments should be the sole function of an instrument rating test.

So, given that you agree with this, why are you selling out by proposing a limited IR with artificial restrictions? :)

[BEagle]

For an Intermediate Instrument Rating appropropriate to the knowledge, experience and skill of a relatively inexperienced instrument pilot, it is only reasonable that the privileges of that rating should be commensurate.

Put simply, all such pilots probably require is a rating which entitles them to fly an aircraft under IFR and in IMC in departure, en route and arrival phases of flight in airspace approved for such use by national airspace authorities. Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

Alternatively, spend thousand of pounds more and obtain the 'full' IR, whose full privileges you will probably never need.

[englishal]

I think there should be an ATP(L) test personally.

[IO540]

Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

The problem with such an approach (no pun intended) is that yet again it will not work with the existing ATC framework - which simply operates on the basis that the pilot has the privileges for the published approach.

There will never be any mechanism in place for anything different, not least because nobody will ever be able to prove at which point the pilot became visual.

This is why the IMCR legal privilege is the published approach. The extra 500ft or whatever is just a recommendation which in a single crew / private flight scenario is totally unenforceable.

[Fuji Abound]

Everyone seems to get terribly excited about flying an ILS to minima.

I would like to know where is the evidence that flying an ILS approach to minima is so very risky.

I have read plenty of FAA accident reports involving ILS approaches. There are many cases of loss of control during the approach phase but very few of these seem to be solely attributable to a pilot who is unable to fly the needles accurately.

Moreover the reality is it is rare for a private pilots to fly to minima. The very personna of private flying is not too fly in the most challenging conditions, unless you are flying regularly in all weather. Unless that is something you regularly attempt it is very very rare to encounter conditions to minima on an ILS.

Why is it we need to regulate personal discipline from private flying.

Personally all other factos being equal I find the final approach of an ILS one of the easiest aspects of instrument flying. :)

[421C]

Europe has structured the ATPL into a free gift to any fATPL pilot reaching 1500hrs with the MCC time etc. So, since the ATPL is basically a bogus thing over here for anybody with a RHS MCC job


This is a misconception IO. The vital bit you omit is that you need to have a Type Rating on a multipilot aircraft. The European system is more restrictive than the US one, in that it is harder to get an ATPL.

The US ATP can be done in two ways. The "GA" route, where you get 1500hrs and the various other hours requirements, the ATP written and then you take a check ride on a piston twin (or even single) just like any other check ride. Alternatively, you do a Type Rating. TRs are all to ATP standard, and when you pass a TR, if you meet the requirements for an ATP, the Examiner can issue you an ATP along with the Type Rating. This is absolutely equivalent to the EASA method - except the EASA method includes 3 additional criteria: you must have the MCC qualification, you must have a TR on a multipilot aircraft and you must have 500hrs of multicrew time.

Englishal,
I think there should be an ATP(L) test personally.
There is. It's the Type Rating you need to qualify for an ATPL.

Think of all Type Ratings as being ATPL checkrides. The US (and other ICAO countries) have an easier/more flexible route to get an ATPL by taking a checkride on a Type that doesn't require a TR.

brgds
421C

[IO540]

This is a misconception IO. The vital bit you omit is that you need to have a Type Rating on a multipilot aircraft. The European system is more restrictive than the US one, in that it is harder to get an ATPL.

The US ATP can be done in two ways. The "GA" route, where you get 1500hrs and the various other hours requirements, the ATP written and then you take a check ride on a piston twin (or even single) just like any other check ride. Alternatively, you do a Type Rating. TRs are all to ATP standard, and when you pass a TR, if you meet the requirements for an ATP, the Examiner can issue you an ATP along with the Type Rating. This is absolutely equivalent to the EASA method - except the EASA method includes 3 additional criteria: you must have the MCC qualification, you must have a TR on a multipilot aircraft and you must have 500hrs of multicrew time.

Indeed, but this just leads to the question I was posing earlier, which is why not tie (in JAA-land) professional pilot status to the ATPL?

Instead of tying it to the IR, which is what happens now and this is the "elephant in the room" that has always blocked any progress being made on a more accessible private IR.

I would also observe that while one needs the MCC TR for the JAA ATPL, this is going to be more or less automatic for anybody with a RHS job (and without a RHS job they have no chance of getting it anyway - short of self funding the MCC hours!). That person (CPL/IR) will already have the TR and can hardly fail to accumulate the other requirements eventually. In fact, in today's pilot job climate, they will accumulate them a lot sooner than the move to the LHS :)

That one can do a "GA ATPL" in the USA (I could do one in my TB20) just makes it even more admirable that the USA is happy with the ATPL as the "professional pilot hallmark", while the JAA ATPL (which is totally inaccessible to a GA pilot) is apparently not good enough for the same purpose over here.

[421C]

The problem with such an approach (no pun intended) is that yet again it will not work with the existing ATC framework - which simply operates on the basis that the pilot has the privileges for the published approach.

There will never be any mechanism in place for anything different, not least because nobody will ever be able to prove at which point the pilot became visual


Neither of those are an issue. ATC does not depend any "single published" minima that all pilots must have the same privileges for - they cope with a variety of operator-determined minima that ATC will have no idea of. ATC/ATIS report the conditions, the operator determines his minima and whether he can accept the procedure and when/if he has to go missed. The list of operator-specific factors that modify the published minima is endless - everything from company limits on procedure types, to weight and conditions determining climb gradient on the MAP to crew currency on a specific procedure, to stabilised approach criteria which mean that ATC can never know for certain, given reported weather conditions and the published minma, whether or not a given aircraft will complete a given procedure.

The IFR system currently works without any mechanism to prove at which point a pilot became visual, so why is this a barrier to any other method?

The actual barrier to an intermdiate IR being meaningfully easier than a full IR is that making the departure and approach minima a bit more restrictive doesn't meaningfully change the Theoretical Knowledge and Flight Training and testing requirements from a full IR.

brgds
421C

[IO540]

Do you think ATC would cope with pilots being unable to accept any instrument approach?

I think that's quite different to having traffic which can in all cases fly the ILS down to 200ft (or whatever), and with nearly all CAT being able to fly it even lower.

Your point about a wide range of operator minima [not being ATC's business] is on the mark but at the same time this is what makes the case for any sub-full-IR privilege very hard to make, because "the other side" is going to argue exactly this line.

[421C]

Indeed, but this just leads to the question I was posing earlier, which is why not tie (in JAA-land) professional pilot status to the ATPL?

I think this is a misconception too. Perhaps there is an element of the IR being a "gatekeeper" for professional pilot evaluation in the UK - because the initial IR test in the UK can only be done by a CAA Examiner. But that is NOT a JAA or EASA requirement. In fact, under EASA, the UK system will not be able to continue, and any Examiner will be able to do an initial IR test. The requirements for the IR stem from several intersecting items of JAA/EASA philosophy and some historical hapstance.
The philosophy is that of approved training organisations and approved courses. The hapstance is that the JAA IR was designed as part of an integrated ATPL course, and not much thought went in to making more flexibile routes more available. There is not really much opposition from the professional pilot community to a more flexible IR for "status" reasons - the pro-pilots "status" comes from the rather difficult requirements for the ATPL, of which the IR is only an element. However, regulators and commerical airpace users are concerned that any user of the IFR system must be able to meet a common, high standard for pilot knowledge and training.

The FCL008 objective, as I understand it, has been twofold.
1. to make the theoretical knowledge for the IR specific to the privileges granted - and not a super-set bundling in other commercial and advanced aircraft knowledge
2. to make the training process by which someone can sit the IR Flight test include a more flexible and competence-based method.
But, the key point is that all IR applicants will need to pass the same TK exams and Flight test - therefore there can not be an accusatioon of "lower standards", which is the kiss of death in Europe on this subject!

brgds
421C

I would also observe that while one needs the MCC TR for the JAA ATPL, this is going to be more or less automatic
But I am not sure what point you are making with this observation? The requirements for getting a JAA ATPL are very demanding. It happens that the flight test requirements can be complied with before the hours requirements. But there is no question that someone getting a JAA ATPL has, following their CPL/IR and MCC qualifications, passed a further test to ATPL standards, their Multipilot aircraft Type Rating. (just to be clear, the MCC is a seperate qualification and course from the TR)

[421C]

Do you think ATC would cope with pilots being unable to accept any instrument approach?
I'm not sure what that question is getting at? They cope with VFR traffic which can't accept any IAP?

I think that's quite different to having traffic which can in all cases fly the ILS down to 200ft (or whatever), and with nearly all CAT being able to fly it even lower
But there can be a lot more variety in the RVR minima for different operators, and all sorts of things limiting minima lower than 200', and all sorts of things limiting minima on an NPA. Again, why is this a problem for ATC?

[englishal]

I'm not sure what that question is getting at? They cope with VFR traffic which can't accept any IAP?
But they are not "IFR".

[Mickey Kaye]

Neither is there any reason for the IR to be taught only at professional FTOs.

"If you don't go for demonstrated competence, the whole thing is bogus.

"Industry interests" is what that bit is about.

And this prevents penetration of the GA market, because most pilots are not within "same day drive there and fly" distance of a pro FTO, so are looking at a residential deal.!"




Totally agree if you can pass the check ride then you are fit to hold an IR full stop.

[bookworm]

Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

So I'll ask you, as I did on the other forum, to identify which aspects of theoretical knowledge, language proficiency, medical requirements are relevant only in the last 250 ft of an IAP. Then we'll understand what is necessary for the full IR but not the limited IR you propose.

[Fuji Abound]

Bookworm

How do you rationalise the lesser training requirments of the IMCr with its excellent safety record? In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

[bookworm]

In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

The disproportionately burdensome training requirements of the JAA IR. Safety in IF comes mostly through experience and currency, not through endless hours of training at an approved school.

[Fuji Abound]

I was considering the merit of setting an exam - if the "student" passes he is good to go, how he achieved the standard is irrelevant. This could be applied to any walk of life and any exam. If a lawyer were to pass the bar exams then he should be good to practice.

The weakness in that argument is that any exam tests only certain aspects of the training a student has received. The exam may not reveal certain weakness and may not cover the whole syllabus. We take a certain comfort that because the student has covered an approved course he has been exposed to all the material whether or not it is assessed at exam level.

Some professionals go a stage further and require the student to undertake a period of mentoring after passing their professional exams.

Perhaps mentoring is an answer. Pass the IMCr, however you can, demonstrate 25 hours of IT in your log six months after and five hours with an instructor and you are good to go with a full IR (the numbers are arbitary).

Bookworm - thanks for clarrifying your position.

[bookworm]

I was considering the merit of setting an exam - if the "student" passes he is good to go, how he achieved the standard is irrelevant. This could be applied to any walk of life and any exam. If a lawyer were to pass the bar exams then he should be good to practice.

I remember a talk from a long retired CAA CFE. He described the procedure of old, where an applicant for an IR would turn up and hire the CAA DH Dove on which the test was to be conducted and pay his fee for the test. He would undoubtedly fail first time, but the examiner would give him useful corrective tips through the test. The next time, he would perform better, but probably still fail. After a half dozen such "tests" the applicant would get quite good, and might well pass. Not ideal, as you point out, hence the introduction of the requirement for mandatory training, which is now at the other extreme.

Bear in mind that the ICAO IR requires only 10 hours of instrument training. It does however, require 40 hours of total instrument experience. It seems unlikely that 10 hours of training would be sufficient for most to pass an IR test, thus the practical minimum training is likely to be 20-25. I doubt many would disagree.

With the IF from the PPL, that leaves about 10 hours of IF to be acquired before an IR can be issued. Whether or not that requirement for extra experience has a safety case is debatable -- I think the stats you quote for the IMC rating are impressive, but are based on sufficiently small accident rates that it's difficult to reach significance. The 40 hours is however, an ICAO standard, and for the sake of such standards, I think the cost of accepting an extra few hours of IF is outweighed by the benefit.

So how does the candidate acquire such experience? One option is mentoring, though that has the issue of who is in command, the mentor or the mentee. Another is that the candidate could be permitted to pick up useful instrument experience in a relatively benign environment which wouldn't require the hardest bits that the IR demands. For example, you might permit the candidate to fly in IMC enroute but avoid instrument approaches...

[englishal]

Though the "en-route" bit is the easiest. We came back from Valenica a while back and the actual routing was dct barcelona dct <somevoronthefrenchborder> dct some other french VOR dct Gurnsey dct SAM then some STAR into Stanstead which became vectors. A couple of flights should suffice.

I think that training should cover all areas of operations at least once- in the case of a full IR, anything that may be thrown at you, from LDA, SDF, Back Course, ILS, NDB, GPS approaches, as well as holds, SIDs and STARs.

However in reality in JAR land, trypical instrument rating profiles go between about 3/4 airports - if you fly from Bournemouth for example, you'll do approaches at Exeter, yeovil, Southampton and maybe Alderney - over and over again until you are good enough to satisfy the examiner you can fly to these airports. Also if you book the examiner on a Friday, he likes Southampton as it is close and he can knock off early (for example).

So if the "cut down IR" only included ILS then the training can be significantly cut down, the theory can be significantly cut down, and the cost can be significantly cut down. If one is then only allowed to file to an airport with Precision approach there is no worries with ATC telling you to shoot the NDB approach and you saying "uuurrrr, sorry". It also prevents one having to buy a Crystal Ball to determine the exact weather at 10:37 at the destination. Seems very sensible to me, and the practical test standards can be equal for the enroute and approach portions.

The addition of an Oral exam, which could test the applicants knowledge on all aspects of the cut-down IR would weed out those who don't really know what they are talking about.

[Fuji Abound]

Bookworm

I love the way in which you have lead the audience into your final line


For example, you might permit the candidate to fly in IMC enroute but avoid instrument approaches...


It is a well constructed post.

I suspect many of us would agree with you were it not that the rumoured proposals contain no proposed transition from the EIR to approach capability. Moreover once again based on the rumours they provide no mechanism for preserving the rights of what some already do.

It has always sat very uncomfortably with me when any Authority proposes to withdraw rights when there is no safety case what so ever for doing so. If the evidence was that existing IMCr holders were involved in a higher than acceptable rate of accidents during the approach phase of an instrument sector I doubt any of us could or indeed would wish to resist the tide of change. However that is not the case.

I would take issue on the size of the population. I dont think so far as instrument qualifactions go in Europe the population of IMCr pilots can be considered small or unrepresentative by any stretch. I do accept that the vast majority of IMCr holders are not flying IAPs to minima, but then how many private IR holders do so? I know a fair few who impose higher personal minima. Moreover if the population has proved they are able to excercise sufficient self regulation so as to achieve a remarkable safety record is this such a bad thing. In reality most professions these days rely on self regulation - aviation is one of the few arenas where pilots are re-tested. Whether aviation has also taken this too far I am not sure. Is there any evidence that since the two yearly flight review was introduced in Europe the accident rate has fallen? Is there any evidence that FAA IR holders who, in the majority self certify currency are less safe that their European counter parts?

As usual there seems to be all too much legislation which doesnt seem to be based on any hard evidence or proper studies of the data. Is this really how we have taken to regulate society? Safety based on politics and commercial interest.

[mm_flynn]

Bookworm

How do you rationalise the lesser training requirments of the IMCr with its excellent safety record? In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

The IMC rating, as currently constructed has a number, of features you would expect to help with the low number of accidents.


The CAA, many instructors and others have advocated the IMCr as a 'get you home' rating.
It has a minimum visibility requirement for landing and takeoff that means you need to be ICAO Class G VMC after you breakout of the clouds
The CAA recommend significantly higher minima than the system minima
The nature of UK airspace restricts the operating envelop in most parts of the country to be low altitude, making knowledge of higher altitude operating procedures and weather phenomenon less relevant.
The geographic restrictions
make understanding procedures in the general sense (vs. UK specific procedures) irrelevant.
restrict typical weather phenomenon to temperate maritime
provide a generally benign and consistent geographic environment




The first three points are likely to have reduced the number of 'challenging' IFR operations to a very small number vs. IR holders. It is likely that the small number of 'Active' [as in using their approach capability for below Class G VMC operations) IMCr pilots helps signficantly to keep the accident statistics down (think Concord moving from safest to least safe aircraft in the world in the course of 15 minutes). To my knowledge, there is no data on relative exposure of IR pilots and IMCr pilots, so it is difficult to make a statement about the relative safety.

The geographic restriction and de facto altitude limitations, I think significantly reduces the relevant theoretical knowledge.

This is offset by a more 'complex' MSA planning requirement in that one must actually look in detail at the charts for obstructions and terrain as you can not use published MEAs and MORAs. However, in most areas of the UK this is offset by the generally consistent elevation (and may be part of the reason for the relative frequency of Southern based pilots collecting granite North of the boarder.

[bookworm]

I would take issue on the size of the population.

It's not the size of the population that's the issue, but the number of accidents. Fortunately, fatal or serious aviation accidents are rare enough that it can take decades to accumulate sufficient statistics to provide the safety case you seem to seek.

Imagine there's a rate of 10 fatal accidents per year. Is a safety measure that cuts the underlying rate by 10% worthwhile? It would save a few lives each year, so a regulator should probably consider it.

But how do we prove the effect of such a safety measure? Imagine we can compare 10 years with the measure (let's say there are 100 accidents) against 10 years without it (let's say there are 90 accidents). Is that a statistically significant reduction? Not even close. At those rates, you'd need something like 40 years with and without the measure to see a statistically significant difference. And that assumes a perfect control, i.e. that nothing else has changed in those 40 years to skew the results.

My impression is that there are very few accidents involving either instrument rated or IMC-rated pilots that can be clearly attributed to IF aptitude -- a lot fewer than 10 per year. That means that, unless we are prepared to write off lost lives simply as data, regulation has to be built to some extent on plausibility of cause and effect as well as statistics.

[Fuji Abound]

Yes, but the IMC rating has been with us for a very long time and a great many hours have been flown by IMC rated pilots.

Are you suggesting that if there has only been one IMC related accident in that time the evidence can be ignored as not statistically sound? It seems to me there is no evidence the rating is unsafe because essentially there have been no accidents. The accident rate of course many increase from zero but applying your logic it would need to increase by a great deal over a long period of time before the rating could be judged unsafe.

How many hours and decades would you want?

Moreover how much more or less statistically sound are the proposed changes? There seems to be no evidence what so ever to support the changes.

It feels to me someone just thought it was a good idea which is in fact exactly what you are suggesting.

[mm_flynn]

Fuji,

With regard to the IMCr safety. In the CAA's last 10 year analysis, considering accidents within the UK (which allows for analysis of all of the facts using the matching AAIB reports) there were two fatal accidents involving IMCr pilots in IMC conditions (1 CFIT, 1 loss of control following an engine failure). There was (from memory) 1 CFIT for an IR rated pilot (ATPL descending from enroute into the sea).

With only 3 fatal accidents in the decade it is a very small sample. As I have already said, there is no indication I am aware of as to even the number of pilots with a current IMCr vs IR - let a lone the amount and type of flying they do.

However, as a very anecdotal comments. When I am out at the airport on a cold and rainy day, the aircraft coming in are (in rough frequency) the local charter operator (CPL/IR, locally based turboprops (unlikely to be IMCr pilots), NReg aircraft (almost surely FAA/IR, and G-reg (of whom a number of the pilots I know are IRs and the rest are IMCr holders) - So I lean towards a view that IMCr holders are small fraction of the pilots flying on bad weather days. Of course, if I were based in the midlands, on a grass strip, with no local charter operator, I might have a very different view.

[IO540]

A great debate, this, and a lot of people are right IMHO.

The "IR traditionalists" will never admit just how much less pilot expertise is required to fly IFR safely, relative to the amount of crap one has to learn to get the IR. And I suspect many of them don't actually know - they are instructors/examiners who have never flown IFR for real, or not in anything remotely recent.

MM-Flynn's points are probably very right, but lots of things are self limiting as regards risk. The IMCR is self limiting due the factors he lists, but the IR (as it would be used by private pilots) is also self limiting, due to

- most GA "wreckage" can't reach the levels at which Eurocontrol routings are reasonably easy to develop (basically, FL100 plus)

- most GA "wreckage" can't reach the levels at which a non-deiced plane is going to be viable enroute i.e. flying VMC above typical N European stratus cloud tops (basically, FL120-FL160), so the risk of (to quote the often expressed fear of ATCOs) the airways clogging up with Cessna 150s is practically zero

- most Eurocontrol routings need oxygen, but a lot of pilots won't use the stuff

- many/most (?) owners of genuinely IFR capable planes already have an IR so there would not be any great pent-up demand

- most IFR GA would be flying in the great empty void FL100-FL200 in which there is almost no enroute traffic, and Eurocontrol routings don't compute through terminal areas...

- private GA rarely flies proper-IFR in really poor weather. In fact, IMCR pilots fly in worse weather; one can fly "VFR" in IMC at 2400ft in a typical OVC007 warm front scenario, but one would not go properly IFR in that because the route will be FL100 plus, but the 0C level will be say FL060 (like today; I've just been up there), and the tops will be ~ FL250, so without proper de-ice this is a no-go because the option of a descent to warm air is not there (short of an emergency declaration, and in much of Europe the obstacle clearance will be an issue) and a climb to VMC will mean transiting through 8000ft of icing conditions and anyway nothing short of a PA46 is going to make it there... Generally, I have flown in much worse conditions on the IMCR than I have flown on the IR.

- the vast majority of long distance touring is done in reasonable weather, because who wants to go somewhere when it is pi55ing down with rain?

However, how relevant any of all this is, I don't know. Rationalising is a wsate of time. The actual obstacles are wholly political...

[englishal]

Stats can be used to "prove" anything you want.

As there is a direct corrolation between the size of hard disks and global temp, does that mean that hard disk size has lead to global warming?!

I wonder how many IMC rating holders have been killed during an approach? This would be telling info because this would determine if the approach is really so dangerous you couldn't trust EIR flyers to carry one out safely?
I knew a reasonably high time IR'd pilot who is now ashes scattered in the Pacific Ocean as he managed to fly into a mountain on an approach in a perfectly servicable aeroplane.

IO is right when he says the IMCr (or EIR...) would be self limiting. I wouldn't choose to fly in really ****e weather - A choice someone flying for someone else can't always make, which is why I reckon the "not authorised for public transport operations" would make a lot of sense.

[IO540]

AIUI, it is politically absolutely vital to not give the "god appointed guardians of IR purity" any excuse for saying they are sharing airspace with less capable users, as that would lead to segregation by airspace class, which would destroy the private IR.

But there is already a precedent for a difference: it is the PPL/IR v. CPL/IR. The former is 7 exams; the latter is 14 exams. In the former exams, there are not supposed to be any "professional flying" i.e. jet or FMS related stuff. Yet both have exactly identical private flying privileges.

And obviously a PPL/IR cannot do PT work anyway.

So I don't see a problem.

[mm_flynn]

In the last decade no one has died flying an approach in IMC in the UK (although one CPL/IR in Oxford came very close).

A number of people have died flying approaches outside the UK (but there is no comperable IMCr population). In general, those have been approaches in and around mountains (which for the most part don't exist near UK instrument approaches.) This goes back to a very big safety feature of the IMCr - its limitaiton to UK only - on most UK approaches, if you use 600 ft as your MDA, you can be 10 miles left or right and still live.

I think the main reason for the differenc in PPL/IR and CPL/IR is that the whole TK structure was designed around commercial training and they 'forgot' about PPL operations. The CPL exam (as I understand it) is actually the ATPL knowledge (ex. MCC).

[maxred]

Thanks IO540, accurate post. I am one of the stats - IMC/NIGHT/Multi, I fly a fully equiped IFR aircraft - transit to Spain /South of France, and will always go VFR. In fact the one time we took an A36 Bonanza to Perpignan, with a 'full' IR pilot in charge, and full IFR flight plan, he nearly killed us in a night approach to the airfield. i.e he got lost on the procedure. I got it visual and then gently assisted.
I enquired a great deal about a full IR. I have resisited, waiting for the EASA situation to develop. What I require as a GA/PPL is a rating that will develop my own skills, keep me as safe as I can be, and let me deal with personal minima. All of this within a realistic budget and achievable within lifestyle constraints.
The one other issue we all face, is recency. To fly full IFR, and be competent, takes a lot of regular flying. I personaly could not do that much to keep current, hence the dilema over the full IR rating.

[BEagle]

1.The CAA, many instructors and others have advocated the IMCr as a 'get you home' rating.

Have they really? I've see that old chestnut in many articles written about the IMC rating, but you tell me where the CAA makes such a statement.

[FREDAcheck]

My requirements may be a bit lower than maxred's, and I really don't want an IR and wouldn't use it enough to be current.

I don't know if I'm a typical IMCR flyer, but I'll bet I'm not alone. I rarely fly because I have to get from A to B - I fly for fun. And flying any distance in low vis at tree-top height isn't. Fun, that is. There are many days in the UK when a flight can be completed above the clag (or even in it), but a VFR flight would be unpleasant and possibly dangerous. An en-route IFR rating wouldn't help. Very often such days have cloudbase down to 1000 feet, sometimes below, which may well be below MSA. (And if the cloudbase were well above MSA, then I wouldn't need the IMCR anyway - I could fly VFR below - so why on earth would I want an en-route IFR rating?)

It's often said that IMCR pilots are not current enough to fly approaches to anything like normal minima - I may be one of those pilots. So I don't fly with TAFs predicting cloudbase below 1000 feet. In the event I get down to MSA and I still can't see, I feel competent enough to fly an approach down to 800-1000 feet AAL. That's exactly what the IMCR allows me to do, and safely I reckon.

IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite". And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.

[bookworm]

Have they really? I've see that old chestnut in many articles written about the IMC rating, but you tell me where the CAA makes such a statement.

This is the closest I've seen:

Safety Sense Leaflet 23: Pilots: It's Your Decision (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=1177)

More than three quarters of the
pilots killed when they lost control in
IMC were flying in instrument
conditions without an instrument
qualification. Disorientation can affect
anyone, particularly those who have
not been adequately trained to fly on
instruments, and kept in practice. It
is important to be able to see and
recognise cloud ahead early enough
to avoid it safely. Even an IMC rating
does not impart sufficient skill for
prolonged, intentional flight in
instrument conditions. Unless you are
in regular instrument flying practice it
should only be regarded as a
minimum skill to ‘get out of trouble’
if an unintentional excursion into IMC
occurs.

"Unless you are in regular instrument flying practice" is, of course, an important conditional.

[mm_flynn]

Thank you BW.

My recollection is GASIL and SafetySense both make these type of comments periodically.

I don't agree with the comments - my point was simply there have been a number of people who advocate this limited role of the IMCr (and a reasonable number of pilots who seem to agree), and this view is likely to result in a lower fraction of IMCr operations occurring in hard IMC than IR operations.

However, I do agree with IO's point that trogging around at 2500 feet in turbulent IMC (and IMCr) is much harder than having a coffee at F100 in an airway and glorious sunshine (an IR).

[englishal]

The reason I say "not for public transport operations" rather than "PPL/IR" is so that a CPL holder, or indeed an FI could hold one. In the case of an FI, they *should* have some sort of instrument qualification for safety but what you find in the UK is that many of them get the IR and a year later let it lapse until they get into the Boeing - something quite rare in the USA where the majority of FI's also have an IR (I don't know any without). A CPL holder who, for example, does stuff like aerial photography, aircraft deliveries etc. and doesn't normally need a full IR, should probably hold some sort of IQ in case the sh*t hits the fan.

A EIR with precision approach capability would be perfect in these cases.

[IO540]

I have resisited, waiting for the EASA situation to develop

Lots of people have done that. Bad move. Even from now, you would have 3 years to the earliest possible EASA attack on the FAA route. 3 years of priceless IFR around Europe.

you tell me where the CAA makes such a statement.

It has been repeated in many publications. As well as bookworm's example, there is GASIL and GASCO - both written to read like they are written by the CAA itself, distributed to the G-INFO database which is obtained from the CAA, so in effect CAA-sponsored.

It's a very tiresome statement to find around the place, over and over.

IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite".

Why not??? What is the actual operational difference? Having to work out Eurocontrol routings?

And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.

Only because one "can" fly around the UK in Class G, at low levels. But a reasonably long trip is possible in the UK, south to Scotland can be 500nm. Why not fly it full IFR?

[FREDAcheck]

Quote:
IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite".
Why not??? What is the actual operational difference? Having to work out Eurocontrol routings?
I expressed myself badly. I meant, it doesn't have to be an IFR-Lite; it's useful even at the more limited scope that I described.
Quote:
And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.
Only because one "can" fly around the UK in Class G, at low levels. But a reasonably long trip is possible in the UK, south to Scotland can be 500nm. Why not fly it full IFR?I put that badly too! I meant that IMCR enables you to fly on many days when you could not fly VFR. Jim Thorpe's en-route IFR rating doesn't, as unless the cloudbase is high enough to guarantee it will remain above MSA then you can't use it. And if the weather is that good, you could fly VFR below.

But nothing wrong with long IFR trips in the UK on IMCR - I've certainly done that myself on many occasions. But I'm cautious to make sure that TAFs are good enough that I won't have to risk an instrument approach below my personal minimum of 800 feet.

[dublinpilot]

AIUI, it is politically absolutely vital to not give the "god appointed guardians of IR purity" any excuse for saying they are sharing airspace with less capable users, as that would lead to segregation by airspace class, which would destroy the private IR.


Agreed.

But I'd also point out that they have no problem sharing the airspace with both IMCR pilots and VFR only pilots, and pilots of deregulated aircraft, when it suits them ;)

Some regularly jump through class G airspace to save some fuel.
Other in fact operate out of class G airspace to make some profits.

They are already sharing the airspace :E

I agree though, that that such an argument is not likely to bear fruit ;)

[Fuji Abound]

"Unless you are in regular instrument flying practice" is, of course, an important conditional.

In any event I would hazard as relevant to an IRated pilot as one with an IR.

I am afraid IF does not make hostages of pilots flying in conditions beyond their currency nor does it check their rating.

[englishal]

"Unless you are in regular instrument flying practice" is, of course, an important conditional.
I disagree.It goes back to the self limiting "private IR".

If one is current then one can go off and fly a profile / approach down to minimums in bad weather.

If one is feeling a uncurrent, then Darwin suggests that most people wouldn't go off and do this. They may head out into some gentle IMC to refresh their skills, or employ an instructor or take a safety pilot with them. Certainly when I haven't been flying instruments for a while, I do the FAA IPC through choice (and to renew my IMCr;)).....

That is the beauty about private flying - one can choose whether to go or not, what weather to go in, and who to go with.

[Fuji Abound]

So back to the original question I asked.

Its odd no one seems to know much about Jim Thorpe.

It seems to me if he is one of those representing UK interests on FCL008 we would have a good idea who he represents, whether he has the mandate of that organisation and how the European en route IMC rating was developed.

Is he on a personal crusade or does he have a much wider mandate?

(and I dont mean in the sense do we agree or disagree with the enroute IMC, we have already debated that one, rather where was the forum in which the idea was developed and debated, and which organisations, if any, support the rating)

[Edited to add which on reflection I must have asked on another thread :)]

[mm_flynn]

Fuji,

Are you an active member (as in attend AGMs, working meetings, write/email/call the executives to express views) of any of the aviation groups?

As far as I can tell, AOPA, IAOPA, PPL/IR, EAS have all had extensive discussions at executive and with involved membership and generally agreed a desired outcome.

I know this doesn't fit with your view (and several others on these threads), but a rating like the IMCr is pretty much impossible to get to fly within the airspace structures and regulatory philosophy of the rest of Europe. This shouldn't really be a surprise given the UKs approach to IFR and consequent airspace logic is pretty much unique in the world.

There may be a need to fudge it in order to facilitate retaining the IMCr in the UK - but that is very different than getting a useful new capability in the rest of Europe.

The key issue is making the IR more sensible, and this would over the long run solve several issues in European GA. On the path, their may be a reason for an intermediate step (and many people continue to argue for that). The 'chocolate teapot' is a proposal in that direction (but is defenitely not an IMCr replacement) - I have no idea what the view of European pilots is to the EIR.

The more UK centric organisations arae mounting the challange to retain the IMCr pretty much unchanged. And I hope they succeed. But the European organisations are working on how to move forward over the long run - which I think is probably the more important victory to secure (and I suspect the EIR isn't really an important part of this objective).

[Pace]

Fuji

been abroad for 3 days so missed this thread :hmm: I think reading over the posts that we are missing the point getting wrapped up in detail.

Yes there are strong proven safety benefits that come from the IMCR but to the VFR pilot. That cannot be stressed enough. The IMCR can in NO way be seen as a MINI IR.

Ok there are those who use it OCAS as one. Usually very experienced pilots who have added their skills over time. For the majority it is a get out of trouble rating no more no less and that is where its safety benefits come from.

Europe could get around the safety angle by incorporating mandatory IFR traing into the PPL syllabus and use the arguement that some instrumenent training adds to safety FOR THE VFR PILOT.

Europe will never ever buy our IMCR as a mini IR. The Europeans are not going to have what they see as poorly trained PPLs risking a collision in IMC with a commercial carrier.

They will expect all in IMC in CAS to be flying to a set standard.
In that light the IFR on top with visual departure and landing is the most we can expect with a European IMCR.

A european IR for PPLs which has the same flying requirements but with un needed elements removed from the study side is the only realistic way we are going to fly IFR in Europe.

If anyone is expecting more frankly we are kidding ourselves. Who is mandated to do what is irrelevant as the on top suggestion is exactly what I predicted for a European IMCR ages ago in these forums.

As I stated then we need to push for an EIR which is achievable rather than shooting ourselves in the foot following a red herring called an EIMCR.

Pace

[Fuji Abound]

Pace

Politics is about the art of the possible. A Euro wide IMCr maybe impossible.

Politics is also about keeping the rabble happy. There will be a lot of UK pilots who have spent £4K or more on an IMCr who will be pretty annoyed if they cant use the rating, the more so those that read the words of EASA / CAA when they briefed the press in London two years ago. EASA could have got away with this one (if they wanted) if there was a safety case for abolishing the IMCr - but there isnt.

It is going to be very interesting to see what they conjure.

[BEagle]

The IMCR can in NO way be seen as a MINI IR.

Of course it is. It is an instrument qualification which includes instrument flying privileges for departure, cruise, arrival and approach segments.

The only restictions applying are use in Class A airways, use outside the UK and 'recommended' approach minima.

Approach minima to lower levels than those recommended for the IMC rating
require a higher instrument scan rate and corrective flying skill due to the reduced beam width of the approach aid closer to the ground. That's why, for example, inexperienced pilots in the RAF holding 'White' IRs are obliged to use higher minima than their more experienced colleagues holding 'Green' IRs.

The UK IMC rating requires proportionate levels of theoretical knowledge, medical requirements, training and testing commensurate with the rating privileges.

It is NOT, as some would try to advocate, a 'get out of trouble' rating. Whereas the daft 'EIR' would certainly be a 'get into trouble' rating.

[Cows getting bigger]

The only restictions applying are use in Class A airways, use outside the UK and 'recommended' approach minima.

1800m? :ouch:

[/Pedant mode off]

It does seem a bit bizarre though. Pilots with IMC ratings are happily and safely operating through the UK on an almost daily basis. They are not bumping into other aircraft and there is no evidence (is there?) of increased erosions/level busts or breaches of regulations by IMCr pilots operating under IFR.

So, where is the evidence that an IMCr (or IR-Lite) would be unsafe in all CAS?

[BEagle]

Recommended approach minima, but absolute meteorological minima for departure and arrival.

[FREDAcheck]

mm_flynn wrote:The key issue [of FCL.008] is making the IR more sensibleThat's not what the Terms of Reference say. Making IR more sensible is just one objective. Considering the need for a European IMCR is another.

PACE wrote:Europe could get around the safety angle by incorporating mandatory IFR traing into the PPL syllabus and use the arguement that some instrumenent training adds to safety FOR THE VFR PILOT.
Pace, I'm sure you're not suggesting that a bit of extra IFR training in the PPL sylabus obviates the safety benefit of IMCR (as that certainly wouldn't be true unless the IFR training were 15 or 20 hours IMCR-like training) but I'm not quite sure what your point is here.

IMCR training not only increases the poor weather ability of a PPL, but also increases the poor weather awareness, or it has in my case, anyway. I believe this means that IMCR holders are less likely than basic VFR PPLs to fly in weather below their capability.

As Fuji says, politics is the art of the possible. Imposing an IMCR on Europe may not be possible. A long-term exception for the UK ought to be, provided UK reps on FCL.008 don't give up on us. And I really hope Jim Thorpe comes to regret ever supporting the en-route but can't land rating; as BEagle says, this is not only counter to UK interests but it's a dangerous proposal.

[David Roberts]

mm_flynn and Pace

Spot on with your comments #60 and #61.

Fuji – re comment #59

People are nominated and appointed to EASA working groups as EXPERTS in their own right, not as representatives of any particular organisation. Though of course it is known ‘where they come from’ so to speak. The nominations are done generally by the OFFICIALLY RECOGNISED pan-EU representative bodies such as IAOPA Europe, Europe Air Sports (EAS) and ECOGAS for the lighter end of the GA sector.

EAS nominated Jim (of PPL IR Europe) in August last year plus two of the other members of the FCL.008 group, one of whom is a UK gliding specialist and the other French.

PPL IR had been active in making representations to EASA well before FCL.008 was set up.

Jim is an expert on the IR. His mission and that of PPL IR, which is a member of both EAS and AOPA UK (afaik), was to have a better replacement for the JAA IR. Nothing more, nothing less. Which BTW looks like it might be realised, but we have to wait for the NPA. There may be pleasant surprises that the proposed new IR will be more accessible for those who would go for the IMCR in the UK. But I won’t enter the technical debate as others will be better qualified to comment on that in due course.

No one was nominated (afaik) and no-one appointed to FCL.008 with the specific IMCR retention or Europeanisation of the IMCR agenda. That would something for AOPA to do through IAOPA Europe, who as far as I am aware nominated Michael Erb of Germany who is on the group.

One has to ask the question as to whether anyone was actually nominated by an organisation other than EAS to be the IMCR expert but not accepted for the IMCR. EAS did not see it as its job as EAS is a pan-EU organisation looking after the interests of air sports and non-commercial recreational pilots across 27 countries, not just the UK. And we had to focus on other issues that needed solving in FCL.008 so there were limits how many people we can effectively secure places for.

As another point, one should treat with a certain (large?) degree of caution comments attributed recently to one of the EASA officers at a publicised conference, to the effect that ‘if IMCR does not happen from within FCL.008 it is that group’s fault’. That is being somewhat ‘economic with the realité’, to be polite.

As I have said to others, tactically the IMCR interests need the UK CAA on your side. There is precedent in principle in the Basic Regulation 216 for having something ‘where national rules allow’ as well as the provisions of Article 14.

One lesson on all this is of course that folks should get involved with the organisations that do have access and influence at EU level, and in advance not arrears, rather than grinding their teeth through a forum. But then I would say that wouldn’t I? As some have said, politics is the art of the possible, which is what EAS practices mostly. With some success in other areas.

In case there is any doubt, I support the retention of the IMCR but the way to achieve that is not how the majority of scribes here suggest.

DGR
President, Europe Air Sports

[FREDAcheck]

Dave,

Are you saying that no one on FCL.008 sees their remit as pressing for the IMCR, despite the fact that this is one of the four objectives of FCL.008?

[bookworm]

"Pressing for" the IMCR? Ahem...

Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges

[Fuji Abound]

In case there is any doubt, I support the retention of the IMCR but the way to achieve that is not how the majority of scribes here suggest.



Thank you for a good summary.

I am interested to know how you believe it should be achieved?

In the event it is not achieved, I am interested in how you think the CAA and the various representative bodies including your own will react if there are a great many IMCr holders who are a little upset that their views have not been represented given the numbers that signed the No 10 petition and given the "assurances" announced by the CAA and EASA in their press briefing.

It occurs to me that it is all to easy to argue that the UK IMCrated pilots are in the minority in Europe. I would argue that since there is almost no private IR flying in Europe as an inclusive part of the total population of private pilots entitled to fly on instruments UK IMCr pilots are a significant member and should be represented as such. If they are not the very constituition of FCL008 may be questionable.

[FREDAcheck]

bookworm wrote:"Pressing for" the IMCR? Ahem...
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
Well, the objective for the IR requirements also starts:Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules.Sounds similar wording to me.

Either way, Dave Roberts seems to be suggesting that no one on FCL.008 sees it their role to make progress on this objective. So who is, or is FCL.008 going to report back "Sorry, we don't have any expertise or interest in one of our 4 objectives, so you'd better form another group to do this."

For Dave to say:No one was nominated (afaik) and no-one appointed to FCL.008 with the specific IMCR retention or Europeanisation of the IMCR agenda.really isn't a good reason to ignore one of the 4 objectives they are mandated to deal with.

[David Roberts]

Please read between the lines of what I said, very carefully, with perhaps one other bit of info. I understand - but I may be wrong - that right at the beginning of FCL.008 the experts were told 'IMCR Europe-wide - no chance' by an EASA official. Hence an alternative tack was taken I guess. Not a case of the experts not taking up the IMCR cause.

[421C]

Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules.


No one ignored that objective. As I understand it, FCL008 has agreed and proposed
1) a significantly reduced TK syllabus for the EASA IR, to reflect only the specific privileges granted by the IR
2) a Competency-based training process to exist in parallel with the Modular and Integrated routes. This would allow some training outside an ATO and some experience building to count towards the total needed to take the test.

This has the advantage that the actual TK Exams and the IR Flight Test are identical for all candidates, so no-one can say that private operators have "lower standards", but it does mean that the process of getting an IR may be more accessible for candidates for whom the current Modular course is too inflexible. There is precedent for such a Competence-based approach under the JAA, eg. converting an ICAO IR to a JAA one. Of course, Competency-based doesn't necessarily mean less training; for some candidates it may mean more than if they undertook a full-time Modular course; but at least the flexibility is there.

The Enroute IR is the proposal for an 'intermediate' step to allow someone to build experience, and to have some use as an enroute-only qualification.

No-one ever promised that FCL008 would "save the IMCr". That has been totally clear from the start and has been repeated on various fora for months. FCL008 set out to find a training process for the full IR acceptable across Europe and an intermediate qualification acceptable across Europe. The EIR may be. The IMCr isn't.
If there had been an objective to "save the IMCr" they would have written that in FCL008's ToR's, instead of "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges"

So instead of sniping at FCL008, the "IMCr campaigners" and AOPA UK should have spent the last year doing what they claim their aim is, ie. "Saving the IMCr", by whatever mechanism they think can achieve that -and which FCL008 never was. I imagine people who feel strongly about the IMCr would love to know what progress has been made in the last year of "IMC campaigning".

[Fuji Abound]

I imagine people who feel strongly about the IMCr would love to know what progress has been made in the last year of "IMC campaigning".


A little difficult I would hazard while we all await the deliberations of a committee shrouded in secrecy and mystery - is this really what open government has come to?

[FREDAcheck]

421C,

Correct me if I'm wrong, but I understand you to be saying that FCL.008 was intended to carry out its objective to review the requirements for IR, but to ignore the objective about IMCR (or at best pay lip service to it).
No-one ever promised that FCL008 would "save the IMCr". That has been totally clear from the start and has been repeated on various fora for months. FCL008 set out to find a training process for the full IR acceptable across Europe and an intermediate qualification acceptable across Europe. The EIR may be. The IMCr isn't.That is, the IMCR isn't acceptable.

If there had been an objective to "save the IMCr" they would have written that in FCL008's ToR's, instead of "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges"But given what you say about the attitude to it, reviewing the requirements of the UK IMCR is a bit pointless, as we already know that the answer is "you can't have it".

You seem to be saying that the requirement to "Review the existing JAR-FCL requirements for the Instrument Rating" will produce results, whereas the requirement to "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC" won't. (The en-route IMC rating is a pointless and dangerous fudge.)

The uncharitable amongst us might assume that FCL.008 is merely an exercise to stop IMCR holders whinging without actually doing anything for them. Sort of Euro Sir Humphrey at his best.

[S-Works]

The uncharitable amongst us might assume that FCL.008 is merely an exercise to stop IMCR holders whinging without actually doing anything for them. Sort of Euro Sir Humphrey at his best.

Amongst many things yes. I did try to point out a long time ago that EASA were never going to accept the IMCr........

[Fuji Abound]

Amongst many things yes. I did try to point out a long time ago that EASA were never going to accept the IMCr........


Indeed you did, and you also said you supported the IMCr as have AOPA.

I am not quite sure why AOPA UK and the CAA are supporting the IMCr if they are so clearly out of tune with the rest of Europe. I do hope they are not simply playing politics. :)

[Pace]

I am not quite sure why AOPA UK and the CAA are supporting the IMCr if they are so clearly out of tune with the rest of Europe. I do hope they are not simply playing politics.

Fuji

I dont really understand what "supporting the IMCR" means. That sounds a bit like save the whale. ie it is something in a distinct shape or form which needs saving.

By save the IMCR are we suggesting in its present UK form for that is what the IMCR is? If thats the case forget it as it will never happen.

The best we will get is a very watered down version of the IMCR which is there in name only.

The danger with that is that it will deflect from getting a more easely achievable instrument rating for the PPL as EASA will make a empty gesture tell us that we now have an IMCR and then forget an achievable European PPL IR.

In my mind the best route forward would be for a modular IR ie a junior version for below RVSM airspace with maybe allowances for experienced pilots to apply for a pre test test. If that is passed then you can take the full examiner IR flight test.

On the exam side a cut down version more designed towards the PPL and able to be completed in a full time 2-3 week course.

That IR could then be added to for Commercial ATP Privalages.

In my mind that is what we should be focusing on and not chasing something that will not happen.

Pace

[englishal]

The danger with that is that it will deflect from getting a more easely achievable instrument rating for the PPL as EASA will make a empty gesture tell us that we now have an IMCR and then forget an achievable European PPL IR.

In my mind the best route forward would be for a modular IR ie a junior version for below RVSM airspace with maybe allowances for experienced pilots to apply for a pre test test. If that is passed then you can take the full examiner IR flight test.

On the exam side a cut down version more designed towards the PPL and able to be completed in a full time 2-3 week course.
Pace,

This is still WAY WAY WAY over the top, and shows typical "European thinking".

Whay have a "pre test test"? Just go for the test and if you fail then you require remedial training and another test.

Why have a "3 week course" for the exams? Nothing is rocket science and I self studied for the FAA IR and FAA CFII exams from the Jeppesen Instrument Commercial manual. No big deal.

UNLESS the EIR has: A precision approach, the ability to self study for the exam, allowances made for previous time and qualifications, the ability to train at your local flying club then it is a non starter and a waste of time. You'll just get previous IMCR holders / Foreign IR holders flying illegally "vfr".

If the aim is to encourage new pilots to get an Instrument qualification then the "course" needs to be as easy, cheap and least hassle as possible.

What really needs to happen is to have this EIR, with a precision approach capability, which can then be upgraded later on.

[Fuji Abound]

Pace

Well, we will have to disagree on this one.

I believe the UK IMC holders are a very powerful lobby. I think that if the IMCr is abolished (without satisfactory grandfather rights into an acceptable replacement) there will be a great deal of discontent. I also think given the stance both the CAA and EASA have taken there will be a legal issue. (I recall your expressing similar concerns regarding the potential loss of FAA priviliges).

None of us seem to really know what will come out of EASA. Personally I am hopeful a solution will be found with which the majority will be happy - and I dont think that will be the en route IR.

In the mean time we can only wait and see.

A few on various forum seem to enjoy hinting at what may be proposed. I learnt a long time ago - either disclose what you can in an open and honest way or say nothing. It is precisely for this reason that the way in which FCL008 has conducted itself is a disgrace. It is important to open government that the committee stage is open to public scrutiny. It seems to me in this case it most certainly is not.

Still I keeping on reminding myself that it is a complete waste of time debating this matter until we know what is proposed other than I suppose it keeps the issue in the public domain. I think I should hold my peace now.

[Pace]

Fuji Englishal

I am talking about a full IR with full IR privalages other than flight into RVSM airspace.

One which EASA could not regard as to lower standards with lower privalages.
I mentioned 3 week full time exam course, obviously the more grandfather rights and allowances the better but we have to be realistic ;)

One fear EASA must have is that if they give nothing there would be an even greater move to FAA N reg already a thorn in their sides.

Pace

[BackPacker]

Looks like this is the consensus, right?

IR "lite" to be used in combination with a PPL:
- Should have the ability to execute a full IFR flight "in the system", including departure, en-route, arrival and approach in all classes of airspace (except RVSM airspace).
- Students should be able to train for this IR within the club environment, no mandatory groundschool for instance, no FTO requirements.
- One or just a very few ground exams, preferably administrable in the club environment.
- If there are minimum flight hours requirements, existing training/qualifications (IMC!) should be accepted towards that requirement under certain circumstances.
- Vastly reduced ground school topics - only the things applicable to a PPL/IR.
- Medical class II sufficient?

Acceptable limitations to warrant the reduction in requirements vs. the full IR:
- Private flight only. Even if the holder of the IR also holds a CPL, CPL privileges cannot be used while under IFR?
- SEP/MEP classes only. For SET/MET/TR aircraft, a full IR would be required.
- No RVSM airspace, no Oceanic airspace?

Furthermore:
- Would it be OK if this were an EASA (non-ICAO) license, only valid within EASA countries? I personally would not mind that.
- Would it be OK to limit the IR "lite" only to precision approaches, with non-precision approaches being allowed after specific sign-off from an instructor?

[David Roberts]

Fuji wrote:

"It is precisely for this reason that the way in which FCL008 has conducted itself is a disgrace. It is important to open government that the committee stage is open to public scrutiny."

No it is not (on both counts). The process is well publicised and established, and is common to all other EASA working groups. Experts are appointed, the group does its work behind closed doors and then an NPA is published for public scrutiny and comment. The comments are then reviewed by EASA and a newly formed review group including user reps and a CRD published for further public scrutiny. Then EASA publishes its Opinion on the proposals to the Commission at which point final representations are made through the channels open to the pan-EU representative bodies (that's what we do, not petitions to No 10 which is waste of time IMHO) ahead of political discussions by member states' representatives. That's pretty open government compared to many alternatives I can quote, even in the UK.

If you want a committee rule-drafting system that is open to thousands of participants and commentators then life is far too short and we would never get any proposals. It would be chaos. The answer lies in getting 'your people' on the committee in the first place, through the appropriate representative body. Even as long ago as the Greeks and the Romans they had worked that one out. Its called politics.

Whilst I can of course criticise much of what EASA is doing, why it is doing it, and often we do through the appropriate channels, at the same time I respect the process that is in place and the officials who implement the process. We work with it to get results, not against it.

Please get real, Fuji.

[englishal]

One fear EASA must have is that if they give nothing there would be an even greater move to FAA N reg already a thorn in their sides.
Ah I see ;)

But this could easily be solved by limiting it to "not for commercial ops, not for use above FL250". That way *most* N reg or potential N operators who use the rating for private flying (irrespective of what licence they hold) would probably not be N reg. You could say "private privileges only" but that may weed out certain groups who could benefit from an IR(L) like this (FI's spring to mind)....unless worded carefully. Not suggesting that FI's could teach this, just that as example you are an aerobatics FI - the weather may be crap but good enough to climb ontop.......

Cheers...

[FREDAcheck]

The process is well publicised and established, and is common to all other EASA working groups. Experts are appointed, the group does its work behind closed doors and then an NPA is published for public scrutiny and comment. The comments are then reviewed by EASA and a newly formed review group including user reps and a CRD published for further public scrutiny. Then EASA publishes its Opinion on the proposals to the Commission at which point final representations are made through the channels open to the pan-EU representative bodies (that's what we do, not petitions to No 10 which is waste of time IMHO) ahead of political discussions by member states' representatives.Yes Dave, I'm sure that's correct. But it isn't satisfactory.

We know (or we've been told here) that the none of the experts appointed are there to support the interests of IMCR holders, and everyone says "Europe won't accept the IMCR so that's that".

This is an issue of great importance to many UK PPL holders, and it doesn't (or needn't) have any negative impact on the rest of Europe. I'm not looking for our representatives to accept European opposition, I'm looking for them to keep on pressing until we get some sort of (acceptable) accommodation. And yes: I've been there myself, done that got the tee-shirt (and war-wounds) from EU committees (not aviation ones), and when it really matters to you it's surprising how often you can win unwinnable battles. There's always an acceptable compromise (and I don't mean the en-route rating).

I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.

It just doesn't seem to matter enough to our guys, or to anyone on FCL.008, which is why I wonder if the membership of FCL.008 may not be consistent with the objectives in its Terms of Reference.

[Pace]

FREDAcheck

Maybe then we should argue for a special case UK only IMCR on thye basis that our maritime island weather requires such a rating?

I frankly think that anything European is a non starter. I would love to be proved wrong but lets get real.

As far as a full IR that is another matter and I am sure there are many who would love to have an achievable IR?

Why have so many abandoned Europe and gone to all the trouble of registering N?

EASA hates N reg in Europe but instead of sitting down and thinking why? and should we crush N reg by offering something more attractive their way is to try and ban something which offends instead of looking at why?

As in any market in the free world the way forward has to be to offer something better, cheaper and more attractive not to take a heavy stick and a big brother one at that!

The IMCR is unique in the UK but we will never get the Europeans to accept it.

We do have an opportunity to get something hammered out closer to an FAA type IR which would be better? ;)

Pace

[FREDAcheck]

Hi Pace,

Fine with a UK-only IMCR; a Europe-wide one would be great, but if other countries are opposed to it then I realise that's unrealistic. But a compromise that allows the UK to keep the IMCR - even if it's a bit of a fudge in EASA licensing terms - would be OK.

And I'm also fully in favour of a "sensible" IR training scheme, but I don't know enough about that to offer any more of an opinion.

[David Roberts]

Will someone tell a technical ignoramous how to show a 'quote' in blocked blue shading as all you experts do. Please!!

[hoodie]

Will someone tell a technical ignoramous how to show a 'quote' in blocked blue shading as all you experts do. Please!!

David, there are two ways (the same way in two forms, really) - either copy and paste the words you want to quote, highlight them and then select the little icon above the reply window that looks like a beige square speech bubble. http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/editor/quote.gif

Or start and end your quote text with [ quote] and [ /quote] respectively. (Without the space before the 'q')

If you want to be really cute, you can put the person that you are quoting's name in the code at the start, like this:

[quote="David Roberts"]


P.S. I, for one, really appreciate your readable and informed input here. Thank you.

[englishal]

Will someone tell a technical ignoramous how to show a 'quote' in blocked blue shading as all you experts do. Please!!
Like this :}

[hoodie]

hoodie is FAA-helpful

englishal is EASA-helpful

:}

[Fuji Abound]

I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.



Exactly. More than 5,000 pilots supporting the IMCr who are being sidelined. That is a dangerous game, not least because I fully intend it will turn into 5,000 individual letters to EASA. That may take some managing.

Forget the IMCr, the name is not important, but what we must strive to achieve are acceptable grandfather rights for existing IMCr holders into a rating that grants similiar priviliges which is not the EIWR as propsoed.

For those that may not remember we caused somewhat of a stir last time - we may excel ourselves this time if the need arises.

So what is the point you may ask? Why the passion? The IMCr is one of the best things that happened to encourage safe GA in the UK. Every single European I have spoken to (that is actually a private pilot and flys) and there are more than a few WHEN they understand the rating are envious of what we have.

I shall be more than happy if EASA come up with an acceptable IR but the history of Europe doing so is against that wish - in the alternative I shall be very pleased to be proved wrong.

[IO540]

As I said before, I think there will be a last-minute reprieve for the IMCR, using some political fudge to save EASA's face on "total European standardisation".

I am sure the UK CAA will support this.

They have said so (I went to that 1/08 CAA/EASA presentation and made copious notes) and it would make sense too, because they know damn well that all that a removal of the IMCR would do is stop UK holders overtly asking for the approach...... a bit like I can't overtly ask for a GPS approach because my IFR GPS is not approach certified (it fully works but I don't have the POH supplement with the proper wording) but I could sure as hell fly the same track (especially if it is all in Class G ;) ).

So you will have traffic flying the IAP/ILS non-radio, (well, they will make a "long final" call, as they are "VFR" ;) ) which is probably OK (as they say, when god made the sky he made plenty of it) but it is going to make some high up people awfully nervous, especially when they get a TCAS warning ;)

Also, aviation has a decades-old precedent, worldwide I am sure, for never stripping any pilot of privileges. Stuff always gets grandfathered - sometimes with a generosity that defies any logic or the subject's actual training record.

The CAA have been tight bastards (especially in their medical department) in holding up a high bar to the initial entry into flying, but once you got "in" they have always bent over backwards to keep you in.

[FREDAcheck]

P.S. I, for one, really appreciate your [Dave Robert's] readable and informed input here. Thank you.Ditto. I may not agree with you (:)) or at least may not like what you tell us, but I do appreciate you and others keeping us informed.

[421C]

421C,

Correct me if I'm wrong, but I understand you to be saying that FCL.008 was intended to carry out its objective to review the requirements for IR, but to ignore the objective about IMCR (or at best pay lip service to it).

But given what you say about the attitude to it, reviewing the requirements of the UK IMCR is a bit pointless, as we already know that the answer is "you can't have it".

You seem to be saying that the requirement to "Review the existing JAR-FCL requirements for the Instrument Rating" will produce results, whereas the requirement to "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC" won't. (The en-route IMC rating is a pointless and dangerous fudge.)

The uncharitable amongst us might assume that FCL.008 is merely an exercise to stop IMCR holders whinging without actually doing anything for them. Sort of Euro Sir Humphrey at his best.


Freda, (to your post #75)
I think the wording is pretty unambiguous (my underline).
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
They did consider whether there was a need to develop an additional European rating. They agreed there was. They defined that as the EIR.

Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules
They also reviewed the existing JAR-FCL requirements for the IR and proposed a more flexible training route.

There was no bad faith in any of this process as far as I can see. It's simply not true to say that the IMCR was ignored, because the outcome of the review wasn't what you want. It's not just some faceless bureaucracy who thinks the IMCr is not acceptable across Europe, people who genuinely care about GA and making it flexible and accessible also think so. It's been explained so many times, I don't know what the point is of doing so again, but I will try.

There are some unique features that make the IMCr "acceptable" in the UK. Primarily, it's that Class A is very prevalent - including all airways and large TMAs - even some not very major ones like the CI Zone. Secondarily, we have a fairly undemanding IFR environment - for example, very little terrain, relatively few thunderstorms, little night flying (because GA airports close early).

Plenty of countries in Europe have low-level airways which are Class D or E and large TMAs which are Class D or C. They won't accept the IMCr in their airways and major TMAs anymore than the CAA will in the UK.

Therefore the IMCr can not work in Europe. Isn't that pretty obvious?
No-one has proposed a definition of IMCr privileges that would work across Europe without the qualifier "where permitted by national laws". But that is a massive qualification which EASA can not accept (as I understand it). Therefore, it isn't that the IMCr was rejected out of hand - it was simply that no workable proposal was found. Without the UK's unique partition of Class A the IMCr becomes......an IR for all practical purposes.

The problem with all the "privilege limitation" options is they are completely misguided in the correlation they draw between limited privileges and training requirements.

Take BackPacker's proposal in post #82
Acceptable limitations to warrant the reduction in requirements vs. the full IR:
- Private flight only. Even if the holder of the IR also holds a CPL, CPL privileges cannot be used while under IFR?
- SEP/MEP classes only. For SET/MET/TR aircraft, a full IR would be required.
- No RVSM airspace, no Oceanic airspace?

It's just a definition of the current IR with some meaningless tweaks. The current IR confers no commercial privileges, it confers the privilege to fly in IFR. The commercial world has its own processes and training for an IR holder to be able to use those skills in public transport. Similarly, there is nothing, nothing at all, in the 50/55hr JAA IR course specific to Type Rated aircraft. This "limitation" is meaningless. Likewise, RVSM has its own specific training requirements - there is nothing in the JAA TK or flight training for RVSM. Or Oceanic operations in IFR (eg. MNPS across the North Atlantic).

BackPacker's "limitations" are effectively those of the full ICAO or JAA or EASA IR - which can't be used in Commercial flight without a Commercial license, or on a turbine aircraft without a Type Rating, or in RVSM/Oceanic airspace without the specific crew training/ops approval. Therefore, this "consensus" proposal is for a full EASA IR. And FCL008 have proposed making that more accessible by removing the remnants of Theory that are not specific to the privileges granted (there is some commercial and turbine stuff in the IR exams currently) and making the training more accessible for private pilots.

Beagle's "limitations" are equally minor in relation to the IR syllabus. Adding a couple of hundred feet to minima is a tweak along one single attribute of IFR. It does not transform the training requirements. The minima are system-based anyway. They are not linked to training requirements until you get into specific approvals for CAT II/III.

Of course, in the UK, adding 200' to minima does mean that pretty much any blunder on LNAV will keep you clear of terrain and obstacles in most places. The rest of Europe simply isn't like that. Flying around the terrain surrounding some airports in Spain, France, Switzerland and Italy on an instrument approach, 200' or 250' added to minima makes little difference to the risks. The brutal truth is that the only thing which makes sense systematically across Europe to fly instrument departures, arrivals and approaches is an Instrument Rating.

The EIR is the only "partition" of IFR privileges that FCL008 could come up with that made sense. And I've yet to read a better proposal from the IMCr campaigners which doesn't conflict with the basic premise of
a) no national variations on FCL privileges
b) no minor or practically irrelevant tweaks in the full IR privileges used to "justify" major reductions in the qualification requirements


I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.


But the question is what fight? I think most reasonable people accept why Europe won't have an IMCr valid across Europe - and FCL008 was about Europe-wide qualifications. FCL008 is a positive outcome for IMCr holders, given an EASA-wide IMCR is just not supportable, possible or realistic. It's positive because it proposes a more flexible/attainable IR and a sub-IR qualification (the EIR) to allow some IFR privileges and a stepping stone to the full IR. That's a big improvement on the original FCL outcome. The irony on the EIR is that all the knee-jerk "chocolate teapot" attacks may actually be counter-productive because the EIR may just be a more acceptable way for the UK to "maintain the IMCr difference", by adding IMCr approach privileges to it within the UK.

Instead of all the pointless angriness and finger-pointing, someone who really cared about the IMCr would get real about what is possible. David Roberts has articulated the process very well.

The best outcome for IMCR holders may be
1. grandfather rights for existing IMCr holders to continue with their privileges indefinately, at best, or for a multi-year transition period
2. transition credits towards the full EASA IR
3. UK-only "extension" of IMCr approach privileges to the EIR

I don't know which of these is possible, but it seems like the best avenue to pursue. Otherwise, if you think 5000 signatures is going to produce a Europe-wide IMCr, you are deluded. All the 3 above are UK CAA issues - not EASA or FCL008 ones. IMCr campaigners should be focused on achieving these objectives rather than trying to win battles on PPRUNE already lost in the real world.

brgds
421C

[mm_flynn]

Very well said C421.

For Fuji, BEagle, FREDACheck and all of the other passionate IMCr holders. Jawboning about a group that is looking at European solutions and has a TOR which any objective reader would agree does not include 'Ensure there is no compromise of existing IMCr holder privileges) is a sterile exercise. Waiting for an output from this group (which is a multi year process as David pointed out) is just letting opportunities slip.

Your time would be much better spent working effectively with the CAA to ensure you and they have solid legal and political opinion about which of
1. grandfather rights for existing IMCr holders to continue with their privileges indefinately, at best, or for a multi-year transition period
2. transition credits towards the full EASA IR
3. UK-only "extension" of IMCr approach privileges to the EIR
is the best stand for the UK and CAA to choose to save the UK IMCr.

I believe the UK AOPA is engaged in this. I assume you are all members, so get involved with a proactive solution - because no European focused process is going to come up with a solution that is 'UK gets to keep IMCr!'

[cessnapete]

Surely the best solution is to have a suitable PPL EASA IR modelled on the FAA IR with a European ground school sylabus. I fly an N Reg. turbo-prop single here and around Europe. The owners 20yr old son with about 250hrs experience, completed the FAA IR training in 4 weeks. He now flys IFR quite safely all over Europe.
The exams being tailored to the job in hand . No Loran Consol and 'draw a gyro horizon instrument', interminable NDB holding and approaches. I have competed both the UK ALTP and FAA IR flight test and the FAA was by far the more useful test. Including GPS, I don't think the CAA has an Examiner yet qualified to test for GPS Approaches!
The huge percentage of US PPL's with an IR versus the 1-2% in UK tells the story.
It will never happen, but just authorise the FAA IR for use in any ICAO Country.

[Fuji Abound]

421C

I have heard more than a few times that petitions to No 10 are a waste of time. This was our Government’s response.

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.

Please note the very clear statement at the end of the communiqué.

Now imagine someone embarking on the IMC rating during the transition period as many are and spending £4K or more on securing an IMC rating. The CAA, EASA and the Dti have stated they will be working together “to ensure that the privileges of the IMC rating holders are protected”. Please note they haven’t said they are working together to “try and ensure”, which they could well have done.

If you were the average UK pilot who really isn’t that interested in politics but was about to invest £4K would you have taken comfort from this assurance given by our Government with the full support of the CAA, EASA and the Dti?

Please note that as matters stand a pilot might well send off his rating application to the CAA at the end of the transition period – a rating that will legislative changes aside remain valid for 25 months. If an acceptable solution is not found it will be interesting to see exactly how legislation is adopted which will enable his rating to be revoked within its life.

This is what Timothy Kirkhope said almost exactly two years ago:

“Scrapping the IMCR would be disastrous.”

Jacques Barrot responded that he shared Mr Kirkhope’s concern and would be at his disposal to ensure UK pilots were not prejudiced.

http://redirectingat.com/?id=42X487496&url=http%3A%2F%2Flesrapports.ladocumentationfrancaise.fr%2FB RP%2F074000415%2F0000.pdf (http://redirectingat.com/?id=42X487496&url=http%3A%2F%2Flesrapports.ladocumentationfrancaise.fr%2FB RP%2F074000415%2F0000.pdf)

You should read this report.

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)

Do you not realise what will happen if the UK does not find an acceptable solution?

This is what EASA said in their terms of reference document in 2008:

During the transfer of the JAR-FCL requirements into the proposal for EASA Implementing Rules, the FCL.001 group and the MDM.032 group (dealing with better regulations for General Aviation) came to the conclusion that the existing requirements for the Instrument Rating seemed to be too demanding for the PPL holder. Additionally some of the group experts were in favor to develop a similar rating as the UK national IMC rating with lesser requirements than the current requirements for the Instrument Rating (IR) which allows the pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR) but in certain airspace categories only.

From which it would seem clear that in 2008 the position was no where near as clear cut as some would suggest unless of course we are expected to ignore EASA’s own terms of reference.

We must forget the emotion connected with the IMC rating. It matters not what the son of the IMC rating is called, what matters is that its privileges are proportionate to the needs of pilots who already hold an IMC rating and proportionate to the needs of pilots in Europe who aspire to fly safely on instruments.

I would implore anyone who reads this thread not to give up on the IMC rating. It is vital that if we are asked to accept a rating that is unacceptable we do not simply cow tail to the political process but are prepared to argue our case. Some would simply have us give up, but then that is always the simplest solution to any problem. I think EASA has already said enough to make it very uncomfortable for them, the CAA, the Dti and a few other organisations if they don’t find an “acceptable solution”.

[FREDAcheck]

Well said, Fuji.

421C, I don't doubt the facts in your post (95), but I don't agree with some of the interpretation, and what seem to be the underlying assumptions.
Quote:
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privilegesThey did consider whether there was a need to develop an additional European rating. They agreed there was. They defined that as the EIR.I don't agree that the EIR can be regarded on its own as an acceptable outcome. It must be explicit that:
...the EIR may just be a more acceptable way for the UK to "maintain the IMCr difference", by adding IMCr approach privileges to it within the UK.as you suggest later. Without that, I don't consider FCL.008 have met their objectives.
The best outcome for IMCR holders may be
1. grandfather rights for existing IMCr holders to continue with their privileges indefinately, at best, or for a multi-year transition period
2. transition credits towards the full EASA IR
3. UK-only "extension" of IMCr approach privileges to the EIR
Option 3 is fine (so long as it really is equivalent capability to the IMCR). Options 1 and 2 are not good.
There was no bad faith in any of this process as far as I can see. It's simply not true to say that the IMCR was ignored, because the outcome of the review wasn't what you want.I'm not suggesting it's bad faith, but given that everyone is busy telling us that the IMCR is not going to happen old boy be reasonable don't ask for the impossible, it amounts to being ignored. This is not simply because the outcome isn't what I want. I simply don't agree that they have done what they were asked.
They won't accept the IMCr in their airways and major TMAs anymore than the CAA will in the UK. Doesn't that doom the EIR as well?
No-one has proposed a definition of IMCr privileges that would work across Europe without the qualifier "where permitted by national laws". But that is a massive qualification which EASA can not accept (as I understand it).To be blunt, EASA must be persuaded to accept it. You also say:
The EIR is the only "partition" of IFR privileges that FCL008 could come up with that made sense. And I've yet to read a better proposal from the IMCr campaigners which doesn't conflict with the basic premise of
a) no national variations on FCL privileges
b) no minor or practically irrelevant tweaks in the full IR privileges used to "justify" major reductions in the qualification requirementsWhere are these basic premises defined? Thing is, you say (twice) that local exceptions aren't allowed, but then finish by suggesting: "3. UK-only "extension" of IMCr approach privileges to the EIR".

I think I agree with you that this option 3 - a permanent UK IMCR - is all we can hope for, but given that EIR seems a non-starter (as it would allow flight in non Class A airways, which you say isn't going to happen), then a UK extension to a non-starter is a bit of a chocolate teapot.

I'm sure you are not confused, but the points you are raising of EASA's views, and the views of other countries, are rather confused and contradictory. Still lots of opening for a compromise that gives us a continuing IMCR in the UK, I'd say. And of course, let's try to get training for a proper IR fixed, too. But as well as the IMCR, not instead of.

[IO540]

It will never happen, but just authorise the FAA IR for use in any ICAO CountryIt is up to each State of aircraft registry what privileges a foreign license or rating gives on an aircraft of that registry.

What you are asking is for say Germany to accept any ICAO IR (just the FAA one would appear discriminary) for a D-reg, for all airspace class.

This would be totally logical but is politically impossible. It would fly in the face of European protectionism (which goes back decades but is why e.g. JAA was set up in the first place) and a raft of elitist attitudes. It will never happen. In JAA-land, only one (rather far away) country ever accepted an ICAO IR in that way and they stopped it a few years ago. The CAA accepts it which also exceptional but only OCAS which is useless.

The politically possible outcomes are

- a European private IR, gradually hacked together under political pressure to reduce the foreign reg scene, and probably together with an attack on the latter scene, to make it "stick".

- a status quo (a climbdown)

The 2nd one is politically the easiest, because nobody actually loses anything except face, and one can always blame that on somebody else. Nobody would gain anything from attacking the foreign reg scene, either. Politicians have to think short-term and what credits they can earn by doing something.

[mm_flynn]

Doesn't that doom the EIR as well?

While I agree with your general logic, the FCL.008 group (which has a range of interests represented) seems to feel it is potentially acceptable (after all, most of Europe allows VFR pilots in these environments and it is not involving IFR in what most countries would perceive as the high workload/ high risk (to self, people on the ground, other aircraft as a result of reduced separations in the approach and departure) phase of flight

To be blunt, EASA must be persuaded to accept it. ["where permitted by national laws" concept]

I am lead to believe this is one of EASA's 'Die in the Ditch' points. To pass a law in their area of competence which explicitly allows individual states to ignore the law is against a fundamental principle that European Law must be applied to all of Europe. This one thing is probably (IMHO) the most difficult item to get accepted due to potentially far reaching implication on the whole nature of European Integration. (see below for the converse)

(I am not a Euro-lawyer so someone else may be able to provide a reference or refute this point)


I think I agree with you that this option 3 - a permanent UK IMCR - is all we can hope for, but given that EIR seems a non-starter (as it would allow flight in non Class A airways, which you say isn't going to happen), then a UK extension to a non-starter is a bit of a chocolate teapot.
Three points,
1 - Option 3 is clearly the 'best' IMCr option for current IMCr pilots who use it as a UK only IR - is it the best achievable? Is the CAA/DfT steeled to have this as their 'Die in the Ditch' position.
2 - Class A airways is a British Anachronism, you should forget they exist in the context of any euro regulation.
3 - I believe enabling a privilege is much easier for Europe to accept on a national level than restricting a privilege. So saying

'Euro-Car licence holders can drive Vans in the UK' is an extension to privilege and would be reasonably received.

'Euro-Car/Van licence holders can not drive Vans in the UK' would be a fundamentally unacceptable restriction of a privilege extended to all Europeans.

[IO540]

I am lead to believe this is one of EASA's 'Die in the Ditch' points. To pass a law in their area of competence which explicitly allows individual states to ignore the law is against a fundamental principle that European Law must be applied to all of Europe.

I think that's 100% correct, but EASA doesn't run the universe. They just run a load of committees, whose proposals are published, go for a comment phase, and then go to the EC for lawmaking.

The known universe is run by the European Commission. That is a bunch of politicians, who work in a different way to the EASA types. This is why when say Cessna wishes to protect the N-reg scene in Europe (which is probably pretty important to their high value jet sales) they are not going to type up a Response # 13556 to some EASA proposal. They will spend 5 figures on a lobby firm operating in Brussels. That's where it all happens (or not) in the end.

It is this lobbying that has successfully brought the EASA proposals to the surface of the political whitewater (or foaming cesspit ;) ) and resulted in the recent open rebuke to EASA which - if the press reports mean anything - will probably result in all hot potatoes going on the back burner and should result in my "status quo" option above.

[Fuji Abound]

421C

You either know something the rest of us dont or you are very out of step - as is Dave Roberts who now seems to have disappeared from the debate I might add. (I wonder why?)

AN official from the European Aviation Safety Agency has said the UK IMC Rating "is as important to the UK as the Mountain Rating is to Switzerland" leading to hopes that it will be saved. However, support for a 'lite' Instrument Rating for GA pilots appears to be ebbing away.

The admissions came from EASA's Deputy Head of Rulemaking, Eric Sivel, during a meeting with the International Aircraft Owners and Pilots Association (IAOPA), and are contained in IAOPA Europe's latest newsletter.

M Sivel agreed that given British weather, the UK IMC Rating was as important to the UK as the Mountain Rating is to Switzerland, and some way had to be found to maintain current safety levels under EASA.

The EASA Working Group FCL008 had been set up to look at the IMC Rating, he said, and if it did not produce an acceptable solution to the problem, then it had failed in its task.

FCL008 is also looking at the long-running saga of the Instrument Rating that was achievable for the average GA pilot. Asked whether the simplified IR was a realistic possibility this time, M Sivel said he did not know. "There is a lot of opposition to it. The pilots unions and the airlines say don't touch it - if anything, make it more difficult."

This is what was said only this month. That seems completely out of step with some of the views expressed here. Either we should believe and rely on what emanates from EASA officials or if EASA is allowing officials to mislead us then clearly EASA is not fit for purpose. At the moment I am prepared to give EASA the benefit of the the doubt -

there have just been too many people in too many officials position saying "a way must be found" for a way not to be found.

Not surprisingly I have much less hope of an IR lite - and this would appear to support my lack of hope. It has been talked about for all the years I have been flying (too long) and before that. It has never really come to pass. I recall Bose telling us of the sweeping changes that were going to take place - of course nothing happened of consequence. They may tinker with the requirements, but tinkering I suspect is all it will be.

With regards the IMC as a well informed journalist has jsut commented:


But if the Agency is now instructed by the EC to leave sub-ICAO/JAR licences to the national authorities, then its future in the UK appears to be secure.


That may well end up being a very convenient way out for all concerned particularly as EASA are struggling with the work they have in hand anyway and moreover it rather conveniently would encapsulate the French mountain rating, the Brevet de Bas and the gliding community that fully intend to carry on flying in cloud despite the fact that they are not required to hold any additional rating to do so, and nor do they conform to IFRs or the move towards compulsory use of transponders.

Finally I am pretty fed up of those who promulgate the usual nonesense about the rating being unsafe. Why pander to the detractors and ignore the evidence. I wouldnt mind your doing so if you (or they) had any factual basis for doing so.

This is what our own CAA has to say about the risks in TMA:

The authority has issued around 25,000 IMC ratings to holders of air transport, commercial and private pilots licences, of which 2,300 are still current. "The IMC rating has been a safety boon," says the CAA. "There have been eight air proxes in seven years involving commercial aircraft in IMC conditions, but none of these involves a GA pilot with an IMC rating."

No suggestion there then that pilots with their IMC rating are causing chaos in class D airspace (effectively the appraoch segement for nearly every airport in the UK from which CAT operates).

Anyway it is still more than two years away IF they meet their deadline. I will worry about it nearer the time.

[Pace]

This is what was said only this month. That seems completely out of step with some of the views expressed here. Either we should believe and rely on what emanates from EASA officials or if EASA is allowing officials to mislead us then clearly EASA is not fit for purpose.

Fuji

As in any comittee many people hold different views and may express those views. That does not mean that they are official EASA statements or policy.

It is probably likely that under the regulations alllowances may be made for "special needs". You mentioned the mountain rating and it is probable that a special needs excemption would be the cleanest way out on the IMCR.

As for the IR Lite you may well be right as NONE of this is about safety and never has been. It is more about protectionsism, self interest and politics.

The whole history of Europe and political leaning has been anti individualism and to have no freedom of the skies.

Given the European leaning its natural instinct is control not freedom. Stick the masses in large commercial people carriers. The big Brother state.

So yes you maybe right the way forward for Europe and aviation will probably be further tightening and restrictions especially against the percieved wealthy individuals who own or fly private aircraft but that isnt good for any of us the IMCR is insignicant in comparison to what we should be fighting.

I am afraid the IMCR is a Red Herring and one where we will end up shooting ourselves in the foot for fighting a blinkered battle.

Pace

[englishal]

This would be totally logical but is politically impossible.
I'm not sure that it would be impossible, and Euroland could do it without losing "face"......

For example if limited to "private privileges only" - which is what the FAA would do to a Euro licence holder - then it needn't impact on "Commercial" aviation in Euroland, which after is is where 99% of the current IR's come from. If the rules then stated that the Foreign IR holder then had to renew their Euro IR (based on) the same way as normal IR holders then in fact it'd actually generate European business.

For one to fly commercially in Euroland, one would still need to do the Euro IR.

[BEagle]

Firstly, you should understand that there isn't a cat in hell's chance of anything 'FAA' being accepted as an EASA way of doing things. If you thought antipathy towards the UK IMCr was bad enough, anitpathy towards anything 'N-reg' or 'FAA' is many times worse. So forget comparison with the way they do things on the other side of the pond.

'Private privileges only' would, quite rightly, be vehemently opposed by all FIs. So forget that for a game of soldiers, englishal, it'd NEVER be accepted.

It is pretty obvious from various responses on this thread that some come from the PPL/IR mafiosi with their blinkered support for the lunatic 'EIR'. Fortunately many of us in the real world are now working with the authorities both in the UK and in Europe to ensure that the actual UK GA view of such a chocolate teapot rating is made plain to EASA.

There are a couple of strategems, both due to other EC proposals, which may well allow us to demand that this whole issue is be put on ice until the potential effects of these proposals have been properly studied.

[Pace]

Firstly, you should understand that there isn't a cat in hell's chance of anything 'FAA' being accepted as an EASA way of doing things. If you thought antipathy towards the UK IMCr was bad enough, anitpathy towards anything 'N-reg' or 'FAA' is many times worse. So forget comparison with the way they do things on the other side of the pond.

bEAGLE

I for one have not indicated an FAA IR in the UK I have indicated an easier to achieve IR which doesnt drop standards which is a little closer to an FAA IR.

As to yourself in the real world good luck as you will equally never achieve anything vaguely like the UK IMCR European wide either.

Your best hope is that the CAA refuse to do anything on the IMCR on the grounds that to elimate it would cause a drop in safety to VFR pilots in our unique weather.

That arguement and tactic doesnt take an Einstein to work out or suggest but Good luck and carry on with the tea and biscuits.

Pace

[Fuji Abound]

Pace

As in any comittee many people hold different views and may express those views. That does not mean that they are official EASA statements or policy.

Now come on Pace, you dont really mean that. One of the ways we run our politics is for senior officials to indicate policy partly of course to assess the reaction but partly to indicate in which direction policy is likely to evolve.

Eric Sivel is no ordinary person - he is deputy head of rule making. I suspect he is an experienced enough person to know exactly what he is saying.

In the same way the Prime Minsister's office however much we may mistrust politicians is not inclined to respond to petitions in a way that is unsubstantiated particulaly when they specifically refer to having consulted with EASA, the DTi and the CAA.

We need to be very careful. There are those who would rather see the demise of the IMCr or its son or daughter for all the wrong reasons. You can bet there are some on this forum. After the comments I have read by EASA, the CAA, the Dti and others, only some of which I have reproduced I have a little more faith. Unfortunately there may also be individuals on committee with less apparent agenda; it is important the voice of private pilots is heard that we will not willingly accept the impostion of regulations that have no case basis in safety, are without regulatory impact assessment and are a restraint of priviliges already held.

[IO540]

Eric Sivel is no ordinary person - he is deputy head of rule making. I suspect he is an experienced enough person to know exactly what he is saying.

I've met him, close up, and I would agree with the above.

However, EASA is just an agency of the Euro Transport Commission and will do what they are told in the end - regardless of what proposals its committees have developed.

[David Roberts]

Fuji "as is Dave Roberts who now seems to have disappeared from the debate I might add. (I wonder why?)" [David please, I am not Cameron.]

Because I have been busy actually working until I decided to take a look this evening at the forum, as 'relaxation'. But I am not replying right now as I am still busy working......or supposed to be!

Other than:
1. 421C has it right.
2. AOPA probably needs to change tack if it is not to blow it.
3. The DfT / CAA almost certainly wrote the response to the No 10 petition. That answer was already available directly from the CAA for those who took the trouble to ascertain their view by sensible discussion. QED

[englishal]

'Private privileges only' would, quite rightly, be vehemently opposed by all FIs. So forget that for a game of soldiers, englishal, it'd NEVER be accepted.

It is pretty obvious from various responses on this thread that some come from the PPL/IR mafiosi with their blinkered support for the lunatic 'EIR'. Fortunately many of us in the real world are now working with the authorities both in the UK and in Europe to ensure that the actual UK GA view of such a chocolate teapot rating is made plain to EASA.
Well I'd accept it, as would probably 90% of people on here. At least it'd give many more people the opportunity to fly IAW IFR in Europe. Something I can't currently do due to the lack of an N on the back of the aeroplane, and despite being as qualified as many of the CAT pilots out there.

Anyway, that is not the issue. The issue is that we have a great opportunity to improve upon the IMC rating. I'd rather the IMC disappeared, but in return we got a useful Eurowide mini IR. I'd be happy for access to "all classes of airspace" and be happy to just fly ILS approaches. At least then I could cross the channel at 10k rather than 3499'.

[Fuji Abound]

Because I have been busy actually working


Well done. Glad to hear it.


421C has it right.


Oh goodie, thats all right then, now we know the rest of us will roll over and accept the position.


AOPA probably needs to change tack if it is not to blow it.


Glad they have had the guts to stand up for what not only they but their members believe in.


That answer was already available directly from the CAA for those who took the trouble to ascertain their view by sensible discussion. QED


I know, I know all petitions are a complete waste of time. As I said earlier I will mention it to Gordon next time I see him. Oh, perhaps you might mention it also to the 4,000 odd pilots that signed the petition.

How many GA pilots in the UK are members of your organisation?

[David please, I am not Cameron.]


I dont mind what you call me and doubtless will. :)

Seriously, you may have to take the view that you have no alternative to play politics. Fortunately I dont and I will argue for the IMCr in the UK or an acceptable replacement which the EIR is not. I might fail but I still believe it is the right thing to do.

Anyway, I am done here, time who tell how this one plays out.

[421C]

Fuji,

Finally I am pretty fed up of those who promulgate the usual nonesense about the rating being unsafe. Why pander to the detractors and ignore the evidence. I wouldnt mind your doing so if you (or they) had any factual basis for doing so.

Then why do you trott out your thing about how safe the IMCr even when no-one has said it's unsafe? I repeat. No-one on this thread has said the IMCr is unsafe.

Can you not understand that the following two positions are not inconsistent?
1. People accepting that the IMCr works safely in the UK with the UK's specific Class A structure and the Class A limitation of the IMCr
2. People outside the UK not accepting the IMCr in their airspace which has a different structure in which Airspace Class limitations can not achieve the same effect they have in the UK.

A number of posters, myself included, have tried to explain our understanding of why EASA isn't going to take the UK IMCr and turn it into a European qualification, and why the basic principles of EU standardisation mean that they didn't just draft EASA FCL NPA17 with a "UK only" qualification, and why, subsequently, FCL008 wasn't able to do so either.

Now, as we have all said, there may be "secondary" methods of getting the UK to hang on to IMCr privileges through transition/grandfathering/opt-out whatever. It would be great if there was such a mechanism. I just don't know what it is.

I know, I know all petitions are a complete waste of time. As I said earlier I will mention it to Gordon next time I see him. Oh, perhaps you might mention it also to the 4,000 odd pilots that signed the petition.
No-one said it was a waste of time. It's your thing again of replying to points no-one has actually made. I only said I didn't believe any petition was going to make EASA publish a Europe-wide IMCr. David pointed out that the reply to the petition didn't seem to add anything to the established CAA position on the subject. That doesn't mean it didn't raise awareness etc.

This is what was said only this month. That seems completely out of step with some of the views expressed here. Either we should believe and rely on what emanates from EASA officials or if EASA is allowing officials to mislead us then clearly EASA is not fit for purpose.
It does seem that there is an inconsistency here. I don't understand it any more than you do. Could the weak link be the reporting of these comments?
The EASA Working Group FCL008 had been set up to look at the IMC Rating, he said, and if it did not produce an acceptable solution to the problem, then it had failed in its task.The other issue may be in the "acceptable". Acceptable to whom?

We need to be very careful. There are those who would rather see the demise of the IMCr or its son or daughter for all the wrong reasons. You can bet there are some on this forum. After the comments I have read by EASA, the CAA, the Dti and others, only some of which I have reproduced I have a little more faith. Unfortunately there may also be individuals on committee with less apparent agenda
This really does read like some sort of odd paranoia. If you have read comments by EASA, the CAA, the Dti, AOPA that give you "faith" then why don't they just turn their faith-giving comments into action? What mysterious force of darkness is preventing them?
The truth I believe is that, in principle, a lot of people are sympathetic to the IMCr but, in practice, no-one has worked out how to preserve it.

Freda,

Where are these basic premises defined? Thing is, you say (twice) that local exceptions aren't allowed, but then finish by suggesting: "3. UK-only "extension" of IMCr approach privileges to the EIR".


I can see how some of that looks contradictory. I think there are two levels in how European laws and rules operate. Firstly, there is a "Primary" level - the regulations that are standardised across Europe and become EU law. Then there is the "secondary" level of national deals/opt-outs/exemptions/whatever that uses a variety of other mechanisms and legal/political methods. EASA's draft rules, developed by the FCLxxx Working Groups, are at the "Primary" level. At that level, I don't think you can have national exemptions etc. I don't know what can be achieved at the "Secondary" level - perhaps a lot - eg. keeping the IMCr or attaching approach privileges to an EIR etc.

brgds
421C

[Fuji Abound]

421C

I am sorry for my robust response to David. I will be frank when saying it dismays me when commentators like David appear to have given up on the IMCr and any replacement (the EIR is not a replacement). I wouldnt mind if he was in step with UK pilots (and even many outside the UK) but I honestly believe he is not. What may or may not be politically achievable is one thing but there are times when you should reflect the wishes of your members. I am not convinced that AOPA supported the UK IMCr two years ago but I suspect if they did not they realised they were out of step with their members and have now had the "guts" to nail their colours to the mast.


But if the Agency is now instructed by the EC to leave sub-ICAO/JAR licences to the national authorities, then its future in the UK appears to be secure.


As I stated earlier here is one possible mechanism. There are others if the Commission wish to use them. We should be pushing for them to do exactly this.

I could set a number of solutions that I believe would be acceptable but there is little point until we have a better idea in which direction EASA will go. One possibility would be a Euro wide EIR with sub-ICAO approach and departure priviliges granted by the CAA in UK airspace.

With regards to the IMCr I understand the safety case perfectly well. If an IMCr holder has demonstrated that they can safely negotiate the arrival into Glasgow what makes you think he cant do so into Maastrich? In fact I think you are entirely wrong - it is the EIR that extends the priviliges of an erst while IMCr holder in Europe because European airspace is not compatible with IMCr holders operating off airways. The reality is many are uncomfortable with a rating that they perceive as being equivalent to an IR lite by another name - which also many do not want in Europe (or historically the UK). The IMCr rather neatly side stepped the issue by keeping IMCr holders out of class A. An EIR with approach and departure priviliges on the face of it does neither. However the imposition of a height restriction and higher minima might have been a better approach to placating the IR lite by another name brigade. In fact it is interesting when you tell some that the minima for an IMCr holder are the same as for an IR - quite simply they are horrified. I suspect the wording the CAA adopted in the ANO was very cleverly drafted.

So much better progress could have been made on this issue if our representative organisations had not just caved in before the first hurdle. Let it not be forgotten how powerful a lobby GA could be. Their numbers are far far greater than all the European commercial operators combined and nearly every single one is a voter. Many are politically or economically active and therefore very influencial. I was pleasantly surprised how relatively easy it was to ask over 4,000 pilots to sign the No 10 petition - that is more than the membership of AOPA UK. I was surprised how with only a little education European pilots were arguing the case for a Euro instrument rating with approach and departure priviliges. It should be to the chagrin of so many of our representative organisations that on these big and important issues they could not find a way of working together, of educating European pilots of the benefits of an IMCr style rating and on lobbying the Commission rather than walking away from the campaign as we have seen on this thread.

As they say in American its the difference bewteen their starting from "of course we can" and our starting from "of course we cant".

[Pace]

Fuji

Part of the problem we have is a misunderstanding eg what the IMCR is. You Beagle and many others see it almost as a British instutution, a rare species which faces extinction and must be saved at all costs.

In reality and this is how the Europeans see it it is a very low quality rating designed to get you out of trouble with minimal instrument training and exams.

Do the Europeans who dont have that rating want such poorly trained pilots in cloud risking a collision with commercial traffic? Because that is how they will percieve it.

UNTIL the day we start to realise that the IMCR is only a set of standards to be met in instrument flying which could be greater or less then we will get no where.

The Europeans have their own IR and viewing the IMCR as a set of low standards far below their IR they are not going to accept it Europe Wide.

As it is purely a set of instrument flying standards and exams as is the IR you can only argue to increase those standards or decrease the IR percieved standards to get something universally acceptable.

We are all after the same thing maybe its just our perception of what we are trying to achieve which is different.

Pace

[Fuji Abound]

Part of the problem we have is a misunderstanding eg what the IMCR is


True.


Do the Europeans who dont have that rating want such poorly trained pilots

.. but there you have it, if you had said "who perceive such poorly trained pilots", I would have agreed with you. The evidence is however poorly trained you or they think they are the evidence does not support you. I just dont understand how intelligent people can so readily ignore the evidence. I recall being told many years a go when a case comes to trial only three things really matter - EVIDENCE, EVIDENCE, EVIDENCE.

Show me the evidence that IMCr pilots are unsafe and I will agree with you. Put the IMCr on trial that it is unsafe and I believe you would fail. Is the training standard for the IR higher - yes of course, but for all sorts of reasons that does not mean it is safer.

Let me ask you this - how many pilots with an IMC have you flown with Pace?

The second issue is do away with the IMCr and what do you think will happen to flight safety? Do you really believe the IR will become more accessable - if it does all well and good but the evidence is not persuasive. Do you think the EIR is an realistic alternative - I dont. Please read the French study because it is a reasonable piece of evidence of what happens when you effectively prevent pilots gaining an instrument qualification. Please consider the history of the IMCr and why it was originally introduced against a great deal of opposition, just as now. The opponents were wrong.

[mm_flynn]

Fuji,

Your argument is much more persuasive with regard to retaining the IMCr for the UK than extending the IMCr privileges.

It is a well supported fact that VMC->IMC incidents are significantly less frequent in the UK then France (and that UK GA is about twice as safe overall). The IMCr is almost surely a significant contributor to this - In any event, it means UK GA utility is much higher then French and Safer (A win win!). There is therefore a pretty solid case to say removing this from the UK will be a massive backward step in Utility and safety (and I don't think anyone has argued against this).

Unfortunately, it is readily demonstrable that the training for the IMCr is significantly less than the IR and excludes subject areas that are deemed by ICAO, Europe and broadly everywhere in the world as relevant to IFR operations in general. So I think Pace's statement is undeniably true - There of course is the question - is it relevant?.

To that end, you are labouring under a misapprehension as to the safety of the IMCr. I have never found the original CAA source of only 1 IMCr accident in IMC. It is patently untrue as even a modest analysis of accident data will show. This is not to say the IMCr is unsafe (exposure data isn't available, it is almost impossible to demonstrate relative safety), and the accident rate for IMCr and IR holders both is fortunately very low (I refer only to UK operations because of the consistent data and relevance to the IMCr). I attach a summary analysis of the last 10 year CAA report on GA accidents. You can see these accidents are rare, and only one was an approach (which from recollection was to low minima and at night). You will note, there is not a single PPL/IR (once again no data suggests the relative flight hours of less than 7.5 tonne ATPL, CPL, PPL/IR, PPL/IMC operations).

Reason Rating Total
CFIT
CPL IR 1
CPL/PPLIMC 1
PPL IMC (not current) 1

Loss of Control
ATPL 1
CPL 1
PPL IMC 2

Of the two CFIT flights involving CPLs, the first (CPL/IR) was an instrument approach where the descent was continued into the sea. The CPL/PPL IMC was a revalidation flight of a PPL IMC holder with a flight instructor.

The Loss of Control accidents are much less conclusive with an equal representation of advanced ratings and IMC ratings. On further analysis, the accident involving the CPL pilot is a Cessna 310 training accident which the AAIB speculates may have entered IMC conditions. In addition one of the two incidents involving a PPL IMC pilot was a Loss of Control following an engine failure in IMC conditions.

The loss of control of the ATPL has no clear cause, the flight was proceeding normally on an IFR flight plan and then suddenly descended 5000 feet into the ground (almost vertically) The AAIB didn’t have any evidence of technical failure or pilot pathology.

This analysis is from the decade after Pace's friend's accident - and overall the accident count related to current IMCr/IR holders was lower for this decade than the previous.

Nothing above says the IMCr is unsafe, equally, nothing suggest that extending the IMCr to a Eurowide rating (with the consequent increase in variety of environments would maintain the safety level). Although, it may increase the safety in France from its current relatively low level.

The case for retaining the IMCr is, I believe, demonstrably sound. The case for getting it accepted around Europe is (IMHO) lacking almost totally in facts - hence the unending depate.

[IO540]

Pace

I don't think I agree with some of this.

In reality and this is how the Europeans see it

Where is the evidence for the alleged European perception

- by pilots
- by regulators

It is clear, from informal surveys, that a large % of European pilots would give their right arm for an "IMCR".

You are no doubt right about the regulators though.

it is a very low quality rating designed to get you out of trouble with minimal instrument training and exams.

I don't agree with that one. I had my 20hrs of IMCR training and at the end of that I was able to correctly fly absolutely every plate that you might have stuck under my nose.

When I started IR training (in Europe) I was flying Eurocontrol routes, with an IR instructor in the RHS to make it legal, and right from the start I knew every bit as much about "IFR" as he did.

Do the Europeans who dont have that rating want such poorly trained pilots in cloud risking a collision with commercial traffic? Because that is how they will percieve it.

Again... need to examine the detail. Enroute, GA flies in the big void between the MEAs (FL070 min, FL100 realistically due to routing issues) and practical oxygen ceilings i.e. about FL200, with a few at FL250. The routings don't get allocated to busy areas anyway. Only in terminal areas will the traffic potentially mix but they are under tight radar control and any monkey with a half decent plane can manage that. And nobody without a half decent plane will be flying IFR anyway - one of the many self limiting aspects of airspace usage.

The Europeans have their own IR and viewing the IMCR as a set of low standards far below their IR they are not going to accept it Europe Wide.

I agree, but that is no reason to describe the IMCR in the adverse terms.

It happens to be a bit of a throw-away qualification for many pilots, because the incentive you have to keep something is according to how hard it was to get it.

If, to get the IR, you have to spend well over £10k, a huge amount of residential hassle, give away your left bollo*k, etc, then you will keep it. So.... how many pilots with a valid IR can you see? Very very few - except high net worth private owners, and those using it for a living. Even most instructors let theirs lapse - until they get an airline job offer.

Whereas the IMCR has been much more accessible, as a natural post-PPL qualification which one can do at one's old PPL school. Just like the FAA IR is in the USA, actually :) But it also means that a lot of people did it and did not look after it.

The key to getting a private IR which achieves any meaningful penetration in Europe will be

- a greatly cut down ground school
- doable in any PPL school (incl. checkride)
- demonstrated competence i.e. not the 50/55hrs minimum dual time
- training doable using a hood (not the stupid CAA screens)

This has all been done to death before but I just like to jump in when somebody has a go at the IMCR :) It served me well for a few years, and I even got a written confirmation from the FAA that it was valid in an N-reg, so I was able to move the plane to N while training for the IR.

[Pace]

>This has all been done to death before but I just like to jump in when somebody has a go at the IMCR<

10540

It may appear that I am having a go at the IMCR when infact I am not. I too enjoyed the IMCR for years and used it in anger.

I would add that for a basic PPL without experience the training for the IMCR is not sufficient for the rating to be used as an OCAS mini IR.

The majority of IMCR holders do use it as a safeguard for VFR flying and not in anger.

The safety benefits are pushed a lot in these threads but lets be clear these safety benefits are to VFR pilots NOT safety benefits to flying in IMC. There is a subtle difference.

I have no fears that we will loose the IMCR in the UK there is too strong a safety case for that to happen.

I have NO confidence at all that it will ever be accepted in Europe. Trying to make the IMCR a European target will only achieve any possibilities of a greater prize an achievable IR to be missed. That will be a LOST OPPORTUNITY.

So against the IMCR? NO! Do I see a larger prize YES! Can we loose that prize by chasing something we will not loose anyway YES YES YES.

Pace

[dublinpilot]

What if we were to take Jim Thorpe's EIR, and make two significant changes:

1. The airlines don't seem to want to share the airways with EIR trained pilots. But under JT's proposal that is exactly what they would be doing, without restriction. In order to allay their fears, suppose we said that the EIR would not be valid in airspace classes, A, B and C.

This would three effects:
A) it would effectively ban all EIR holder from airspace across Europe above FL195 (which is all moving to class C, most of it is already there). For the airlines this largely means no mixing it with EIR holders enroute which has to be a big improvement for them over JT's proposal.

B) it would ban EIR holders from busy terminal airspace, which tends to be class A or C.

C) it would allow regulators in countries that did not want EIR holders mixing it with commercial traffic the option of upgrading their class D airspace to class C, and effectively ban EIR holders from controlled airspace. Those that did wish to allow them could downgrade any class C to D. There isn't all the much difference between Class D and C anyway.

As for class E-G, well VFR pilots are already mixing it with commercial traffic here, and don't even require transponders nor two way comms!

Of course this would also allow EASA to have it's one size fits all for European airspace.

It would surely also be much to the 'safety benefit' of the airlines.

Regulators would have little cause for complaint, as they could effectively ban EIR holders from controlled airspace by upgrading class D areas to class C (They will be mixing it with non-transponding, non-radio VFR traffic in class E anyway, so I can't see much objection to mixing it with EIR traffic which will have to have a transponder, and will have to have two way comms).

2) In return for the above, EIR holders would be allowed to do approaches in IMC. Of course this would only be in airspace classes D-G

This would make the rating (as a stand alone rating) much more useful, as it would allow the rating to be useful in itself, in classes D-G.

It would allow those working towards the full IR to practice approaches to less busy airports.

From the airlines prospective they would only be mixing it with EIR holders at less busy airports (airports in airspace Classes D-G).



Would this have a chance of succeeding?

Would the banning of EIR holders from Class A-C cause logistical problems?

dp

[BEagle]

So basically bin the worthless EIR and instead have a pan-EC IMC Rating, whose use within national airspace would be as permitted by individual EC member states under their own national laws........?

That's what I've been saying for over 12 months now.....

Except that the approach privileges should be commensurate with the experience, training and testing of the pilot.

[mm_flynn]

What if we were to take Jim Thorpe's EIR, and make two significant changes:

1. The airlines don't seem to want to share the airways with EIR trained pilots.
I think your starting point here is wrong on a number of counts.

In most of Europe GA are able to mix in the airways with CAT today (just not in IMC)
FCL.008 seem to think that the airlines and regulators ARE willing to accept EIR trained pilots operating IFR in IMC during the enroute phase.
Point 2 above is not surprising given the proposed EIR knowledge requirement is significantly greater than the current IMCr
The concerns around extending the IMCr into Europe are rather more generalised than just airlines trying to maintain a private club.

Also, in the environment you propose, the UK would have a logic to move to Class C around air carrier airports for 'European Harmonisation' so this could be a pyrrhic victory strategy for saving the IMCr.

There should be two very clear focuses of effort
First, moving to a sensible training, testing and TK structure for instrument flight in Europe - which would improve safety, reduce the relevance over the long run of sub-ICAO IR qualifications and help contain the growth in N-Reg aircraft. (I do accept history is not on our side on this one)

Second, a robust defence of the IMCr, almost surely built around the CAA,DfT, UK securing a right to add additional sub-ICAO privileges to EASA licences valid only in UK airspace. This may result in all States having this privilege and any State that wished could introduce or recognise the IMCr (but given no one has yet picked it up - this is aspect is likely to be a long shot).

The quest for a mixture of training, TK, testing and privileges to build a sub-ICAO IR seems unlikely to succeed. The non-IR rated GA community (UK in particular) is opposed to any meaningful privilege limitation and the regulators are opposed to moving general IFR operations to a sub-ICAO training and testing level.

[M609]

There has been a few mentions of higher approach minima.

How much lateral error in navigation is that meant to remedy? I mean, obstacles close to centerline can sort of occur at 3000ft above OCA as well as at OCA :bored:

[mm_flynn]

There has been a few mentions of higher approach minima.

How much lateral error in navigation is that meant to remedy? I mean, obstacles close to centerline can sort of occur at 3000ft above OCA as well as at OCA :bored:
If you look at UK approaches and consider a 5 mile lateral error and apply the recommended IMCr limits, there are very few actual collision risks and those that do exist seem (from my limited look at the plates) to be linked to being early on a step down fix. If you again look at any required routings (SRD/SID/STAR) to the platform altitude in the UK, you can, for the most part be +/-20 miles and still be ok

If you apply the same logic to approaches throughout Europe, there are a number where it does make a difference.

[IO540]

The problem with higher minima is that they cannot be enforced and are thus meaningless. Nobody but the pilot can ever know at what point he became visual.

The CAA is not stupid (well, a lot of people have left but I am talking about years ago now ;) ) and this is no doubt why they have not legislated a higher minima for the IMCR.

Only in a multi crew cockpit / AOC scenario can different minima be "enforced" because in that case the other pilot is supposed to spill the beans on the one who busted the minima applicable to that situation.

I think that, regarding making a mistake, there is a fair number of places one can get killed at. I am sure you will hit the ground on the Shoreham 20 for example if you step down one step too early. I once plotted that approach on the O/S 1:25k map and it was only a few hundred feet above the hill.

[BEagle]

IO540, no minima can ever be 'enforced'.

In a single pilot aeroplane, the only 'enforcement' is down to the self-discipline of the pilot.

[mm_flynn]

I think that, regarding making a mistake, there is a fair number of places one can get killed at. I am sure you will hit the ground on the Shoreham 20 for example if you step down one step too early. I once plotted that approach on the O/S 1:25k map and it was only a few hundred feet above the hill.Shoreham is one I was thinking of with regard to the Stepdown risk. However, if a pilot maintains 200 feet above the published minima (as recommended for NPA - taking the point about the inability to enforce this), the OCA/MDA looks like 800 + 200 = 1000 recommended MDA. 5 miles early on the stepdown and you skate 140ft above what appears to be an antenna (however, if you are at the MDA still in clag why continue along lowdown, you might as well go missed. If you are not in the clag, then the visibility should be above 1800 m (which is VMC) so you the odds of impact are pretty low. This tower seems the highest thing on the chart.

Most of the approaches in the UK are like this. Pretty forgiving if you adopt the recommended higher minima.

Out of interest, any suggestions on the 'highest CFIT risk' approaches in the UK (i.e. where an error in lateral positioning or altitude holding creates a high CFIT risk )

[englishal]

1. The airlines don't seem to want to share the airways with EIR trained pilots. But under JT's proposal that is exactly what they would be doing, without restriction. In order to allay their fears, suppose we said that the EIR would not be valid in airspace classes, A, B and C.
Forget it. This would lead to IMC type low alt, non clearance, IFR in the UK as we'd be stuck below class A.

As the CAT doesn't want to share airways with "EIRs" then that is easy to fix. Make the practical test standards the same for both. How difficult is it to fly in an airway with precision? It is not.

My suggestion (again) is to limit the rating to precision approaches. Less to learn, cheaper to learn, and can be tested to the same PTS as the full IR.

Then everyone would be happy - the skygods of this world couldn't complain, the airlines couldn't complain, we wouldn't complain. Seems SO easy.....

(and give FAA IR holders one for free :ok:)