IMC: 'Hung out to dry by our own side'

[drambuster]

summary of AOPA article in December magazine:

EASA recently held a working group meeting to determine, inter alia, the future of the IMC rating. The UK was represented by a Mr Jim Thorpe of Europe Air Sports and Deputy Chairman of PPL/IR Europe

Despite there being 23,000 current holders of the IMCR, Mr Thorpe has managed to convey to his European colleagues that there is no support for the rating in the UK :eek:

The Europeans have mistakenly gained the impression that the IMCR is equivalent to an IR with just one fifth of the training . . . . and that we can all trolley around up there in the airways with their commercial traffic. No wonder they are so opposed to it with this blatently misleading briefing that has been coming from certain quarters (possibly attached to the entirely independent PPL/IR org who of course have no agenda of their own to peddle :rolleyes:)

Thorpe has told them that British pilots "will prefer a proposed En Route Instrument Rating for which a course of theoretical exams must be passed before the holder is allowed to fly in the cruise in IMC, with no approach and landing training or privileges" (no doubt this silly concept was dreamt up by a certain Mr J Thorpe - £25 explanatory manual available from all good bookshops)

At the meeting, the only person who tried to raise the UK GA's overwhelming support for the IMCR was Dr Michael Erb of AOPA Germany but he received no support from the UK delegates and so "it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates"

Sadly the meeting had been nobbled so as to exclude AOPA UK - all our seats were filled by Thorpe and his cronies.

Fortunately, the Germans seem to have a full measure of integrity not only demonstrated by Dr Erb, but also the Deputy Head of Rulemaking, Mr Eric Sivel, who was obviously surprised by the cleverly orchestrated hatchet job on the IMCR by the UK delegation . . .. . . . . and has agreed to meet urgently with AOPA UK "to ensure there are no further misconceptions about the UK rating".

Frankly I think current members of PPL/IR Org and Europe Air Sports should urgently change their management and to recruit exclusively Germans who seem to have adopted en masse our British sense of fair play. We, on the other hand, seem to have turned into a bunch of weasels . .. . .. . .. .

However, should you wish to abandon your IMC rating and to head in your Warrior for the Airways with a full-on gold standard IR then please contact Mr Thorpe at [email protected]

Drambuster

[Fuji Abound]

If this is true (and I am not suggesting it is not) PPL/IRs membership should have the guts to call an emergency meeting and sack Mr Thorpe. There are a few on here that are PPL/IR members - it will be interesting to hear what they intend to do. (I was a member and resigned over this issue).

AOPA UK should write to FCL008 and make their position clear. They should ensure their letter is in the public domain. There are more than a few AOPA UK members on here - it will be interesting to hear their intentions.

[mm_flynn]

I am support of the IMCr, however, the latest magazine (if it is really reflective of the AOPA leadership) demonstrates how catastrophically they have been managing this issue.

AOPA UK seems to have had a view that they didn't need to lobby the CAA/EASA/Dft/ et al to agree to national ratings being attached to EASA licences (and all of the other strategies to keep the current IMCr running post EASA FCL). With a very naive view that the words "Review the requirements of the IMCr and other national IFR ratings, conclude if there was a need to develop an additional European rating...." meant "find a method to retain the current IMCr unchanged" AOPA UK seems to have sat on its backside wishing for an impossible outcome.

Then to present as fact a clearly risible argument, that in no way match what their membership wants continues the simplistic, at best, campaign.

Despite its 27-year success record in the UK, much of Europe does not want the IMC rating, Partly because of the mistaken belief it allows IFR flight and access to controlled airspace

The idea that the privileges of the IMC rating are essentially the same as those of the IR is so wide of the mark that IMC rating holders must be aghast.

Certainly the vocal UK supports want the vast majority of the privileges of an IR, and specifically they DO want to plan IFR flights in proper IMC, they DO want to execute approaches in controlled airspace, they DO want to fly in controlled airspace (but accept they can't fly in Class A) (and would object vigourously if the air carrier airports moved from Class D to C airspace). They DO want to have the right to fly these approaches down to the same MDA and DH (but to a higher minimum vis).

Mapped into Europe, these are 'essentially the same as those of the IR' and 'allowing IFR flight in controlled airspace'.

They then go on to say

The purpose of the IMC rating, to save pilots who inadvertently fly into IMC by helping them keep control of their aircraft and returning them safely to the ground, has been utterly misrepresented.
Which just perpetuates the 'its a get you out of trouble rating not something you use to plan to fly in IMC' - While there are no doubt many who use the IMCr in this way, THE OBJECTIVE of saving the IMCr is to save the ability to plan and fly in IMC and shoot approaches!

This rhetorical strategy very badly misrepresents the objectives of saving the IMCr and as negotiations unfold will be demonstrably untrue (the enroute rating with some training of approaches as an emergency procedure - would accomplish AOPA's quoted objectives - BUT THAT ISN'T WHAT PEOPLE WANT!!!)

Hopefully AOPA has woken up to the challenge and will get its act in gear to negotiate the ability to attach national differences or sub-ICAO ratings to EASA licences!!

[bookworm]

If this is true (and I am not suggesting it is not) PPL/IRs membership should have the guts to call an emergency meeting and sack Mr Thorpe.

And if it's not true, should AOPA "call an emergency meeting" and sack those who have persistently libeled Mr Thorpe?

[skydriller]

Originally Posted by AOPA Mag
Despite its 27-year success record in the UK, much of Europe does not want the IMC rating, Partly because of the mistaken belief it allows IFR flight and access to controlled airspace

Who are they talking about here? If you talk to European PPLs and explain what an IMCR is, I think you will find that most of them would love to have the privelleges of an IMCR available to them.

[ab33t]

As posted in the original opening thread , the Germans seem to have a handle on what the IMC entails , how did the negotiations end up with someone that is clearly not there to lobby for the IMC , that is the question I would liked answered

[Donalk]

Sadly the meeting had been nobbled so as to exclude AOPA UK - all our seats were filled by Thorpe and his cronies.



Sadly this says quite a bit about the effectiveness of AOPA UK when they fail to rustle up an invitation to the meeting.

[P.Pilcher]

I can visualise Ron Campbell turning in his grave. RIP Ron - if you can!

P.P.

[Fuji Abound]

And if it's not true, should AOPA "call an emergency meeting" and sack those who have persistently libeled Mr Thorpe?


and if it is true will Mr Thorpe have the integrity to resign given that presumably he is well aware of the No 10 petition that we organised last year signed by more than 4,000 pilots.

Of course as I have said before if these meetings were open to public scrutiny like our own select committee meetings we wouldnt have to speculate whether or not it was true - so much for open government. It rather makes you wonder what would come to light if we examined their expense claims. :)

[Whopity]

Surely this is a classic example of UK Aviation with numerous minority groups all pushing their own agendas with no regard for the broader community. It also illustrates how badly UK GA is represented!

With no IMC, rating more people will be killed chancing their arm in marginal weather, due to the lack of training.

[Cows getting bigger]

This is a subject that is rather important to me (and many others) so, at the risk of sounding flippant, WTF is going on and can anyone point me towards hard facts rather than unhelpful mud-slinging?

[Sir George Cayley]

If you look at how EASA works it's processes are in fact transparent. Though I admit that navigating their website and finding the right bits is still a nightmare.

You must also see things from the European standpoint, which emanates from Brussels and indoctrinates the Commissions executive agencies such as EASA.

Remember that EASA is still very new in regulatory terms. Their remit is being widened in stages; first was a/c manufacture and maintenance, next Air Operations, then Licensing and this will be followed by airports and ATC. Each stage is presaged by a change in European Law; adoption of the Rules follows a period of public consultation.

Pre-consultation working groups are formed BY INVITATION from EASA to draft Implementing Rules, Acceptable Means of Compliance and Guidance Material.

This has been going on for quite a long time and it has always worried me how little awareness of the process and consequences for UK aviation there is. And I mean some organisations as well as people like you and me.

The problem for EASA is that they don't know who to talk to. The know they don't want to talk to existing national entities like our CAA in isolation, because the EU is inclusive and wants the industry view as well.

A bit like when you move to a new area it's not easy to know which is the nice part of town and which to avoid.

Some organisations have simply played a better game of being good Europeans, doing the Brussels coffee-shop-lobbying culture, and elevating their stature so that EASA give them an invite. Others have been less successful. It's a people thang:) as much as technical competence or ones domestic standing. Anyone getting to know M. Sivell (he's French I believe) has literally 'swum the channel' as he's quite a character.

Another problem is the way we Brits have previously responded to Notices of Proposed Amendments (NPAs). Sending a response along the lines of "over my dead body" 3479 times is not the way forward and actually irritates the poor workers who have to include these in the Comment Response Document (CRD) and guess what? Those all counted as 1 reply.

Contrast this with responses that; raise an objection, explain how the Basic Regulation creates the problem, the Enabling Rule further adds confusion and how the Implementing Rule is too detailed and then proposes viable AMCs to provide proportionate levels of safety.

Which would you prefer to deal with? Answers on a 50 euro note to me please.

Things are happening now in Cologne which will affect UK aviation for years to come. All I can say is log on to the EASA website, look for the Rule Making pages and respond appropriately. I have to warn you that some battles may already be lost, though.

Sir George Cayley

[Fuji Abound]

Sire George - I am in abosultely no doubt you tell it as it is.

However I am fed up with this sort of politics, as are I suspect a lot of people. It is up to those that sit on these committees to go out and listen to pilots views, take note of things like the No 10 petition and the views of our own CAA. If they dont they have failed - it may not do us much good in the long run, but it still needs to be said.

[skydriller]

Sending a response along the lines of "over my dead body" 3479 times is not the way forward and actually irritates the poor workers who have to include these in the Comment Response Document (CRD) and guess what? Those all counted as 1 reply.

If 3479 individual responses (or whatever, I know its a made up number!!) from different people do indeed get counted as one response because the premise of the reply is similar, then there truely is no democracy within Europe. The fact that 3479 people have responded in a similar way should tell them something!!:suspect:

I will say it again - Tell any European PPL what an IMCR is, and then ask them whether they think its a good idea, and you will get a resounding "YES, wish we had that!!" in response.

Now, how does one get that response over to those in power in EASA?

[421C]

Of course as I have said before if these meetings were open to public scrutiny like our own select committee meetings we wouldnt have to speculate whether or not it was true


What difference would that have made? You want everyone to listen to your views, but in an endless stream of posts and threads I have never observed you take any feedback or input whatsoever. Your own listening capacity appears to be zero.

Last May Jim took the trouble to get permission from EASA to publicise the interim outcome of FCL008. It was clear and NOTHING has changed to provoke this recent torrent of bile.

1. FCL008 was not proposing a Europe-wide IMCr for all the reasons that have been articulated to you ad infinitum

Martin Robinson himself said in the GA article "AOPA UK was not seeking to foist the IMC rating on the rest of Europe, as some had claimed, but it was extremely concerned to retain it, or else adopt a rating with almost identical privileges, in Britain"

2. FCL008 did not have access to any mechanisms to create either a national-only rating or a "limited by national discretion" rating

3. Therefore, the only two outcomes of interest to an IMCr holder that FCL008 could achieve would be a more accessible full IR, and a sub-IR rating that was acceptable/workable across Europe. The EIR was the best such rating that could be agreed.

All of this has been in the public domain since May. If you or AOPA, or Eric Sivel for that matter, had some mechanism for "saving" the IMCr consistent with 1 and 2 above, then you should have publicised it. The AOPA article admits that they don't know what the mechanism should be - yet castigates FCL008 for not having some magic potion to come up with such a mechanism.

Given it has been clear for 6 months now that FCL008 was not going to "save the IMCr", why don't you, as a self-proclaimed IMCr campaigner, tell us what you have been doing to achieve this objective? Similarly, AOPA UK appear to have sat on their backsides for 6 months and woken up now to an outcome and terms of reference they have known about (through their IAOPA representative) for most of 2009. An "urgent" meeting with Eric Sivel in December 2009. What have they been doing all year?

The rest of the AOPA article is irrelevant. It deals with some recent personal comments about the IMCr made by Jim Thorpe. He is not the "UK" representative, he is a European representative who happens to be from the UK. Amazingly, FCL008 had topics other than the IMCr to work on - gliding and the full IR. What makes the IMCr nutters think there should have been some FCL008 "vetting" so that only someone who had a prescribed set of opinions could sit on a committee?

I happen to like the IMCr because I both believe it is safe and effective, and personally had hundreds of hours of IMCr-holding flight in which I used the rating to the full. I hope the rating can survive, but I despair over the mix of obtuseness, naivety and malice shown by some IMCr campaigners; especially in this attack on Jim.

The man isn't a huge fan of the IMCr, his comments are balanced in the sense of acknowledging strengths and weaknesses. Big deal. Wake up and accept that some people think the IMCr is not great. Despite my personal and positive experience, I have heard first hand from too many experienced IFR instructors, whose views I respect, that the standard of many IMCr holders they fly with is poor or, even, shockingly poor. No matter how many "FACTS" you post, you are not going to sway first hand experience of this sort that will shape people's views.

brgds
421C

The only possible counter to my points above are the Eric Sivel comments which imply that FCL008 both had the mandate and the tools to "save the IMCr" but chose not to use them. I believe this to be plainly and simply untrue. I do not know whether Mr Sivel was misreported, misinterpreted or misguided in this respect. I suspect we will find out.....

[421C]

By the way, little of Drambusters interpretation is true

summary of AOPA article in December magazine:

EASA recently held a working group meeting to determine, inter alia, the future of the IMC rating. The UK was represented by a Mr Jim Thorpe of Europe Air Sports and Deputy Chairman of PPL/IR Europe [Not true. Jim was not a "UK representative". He was there as a European representative, with a specialised knowledge of IR, not IMCr matters. The IR was amongst the topics on FCL008's mandate in case this point has been missed by anyone....]

Despite there being 23,000 current holders of the IMCR, Mr Thorpe has managed to convey to his European colleagues that there is no support for the rating in the UK http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/eek.gif [Not true. The article says that but it is not a quote and I don't believe it. How could anyone on FCL008 or in EASA not be aware that IMCr holders passionately support their rating?]


The Europeans have mistakenly gained the impression that the IMCR is equivalent to an IR with just one fifth of the training . . . . and that we can all trolley around up there in the airways with their commercial traffic. No wonder they are so opposed to it with this blatently misleading briefing that has been coming from certain quarters [Not true. This was not a "briefing" to FCL008 and if anyone had attempted a factually misleading briefing I have no doubt IAOPA's representative would have corrected it](possibly attached to the entirely independent PPL/IR org who of course have no agenda of their own to peddle :rolleyes:) [instead of insinuating with smileys, why not state what you believe this "agenda" to be]

Thorpe has told them that British pilots "will prefer a proposed En Route Instrument Rating for which a course of theoretical exams must be passed before the holder is allowed to fly in the cruise in IMC, with no approach and landing training or privileges" (no doubt this silly concept was dreamt up by a certain Mr J Thorpe - £25 explanatory manual available from all good bookshops) [Not true. Neither Jim nor anyone else has claimed the EIR is prefered]

At the meeting, the only person who tried to raise the UK GA's overwhelming support for the IMCR was Dr Michael Erb of AOPA Germany but he received no support from the UK delegates and so "it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates" [Personally I believe this to be a misrepresentation]

Sadly the meeting had been nobbled so as to exclude AOPA UK - all our seats were filled by Thorpe and his cronies. [Not true. Whose seats are "our" seats? AOPA was represented through IAOPA by Michael Erb. There were other UK nationals on FCL008 other than Jim. BTW who are Jim Thorpe's cronies? This is conspiracy nutter stuff. The composition of FCL008 was published publicly last year.]

Fortunately, the Germans seem to have a full measure of integrity not only demonstrated by Dr Erb, but also the Deputy Head of Rulemaking, Mr Eric Sivel, who was obviously surprised by the cleverly orchestrated hatchet job on the IMCR by the UK delegation . . .. . . . . and has agreed to meet urgently with AOPA UK "to ensure there are no further misconceptions about the UK rating".

Frankly I think current members of PPL/IR Org and Europe Air Sports should urgently change their management and to recruit exclusively Germans who seem to have adopted en masse our British sense of fair play. We, on the other hand, seem to have turned into a bunch of weasels . .. . .. . .. .[I underlined 'full measure of integrity' and 'British sense of fair play' as an ironic reference to how utterly lacking these were in the misrepresentations peppered through the AOPA article and amplified on this thread.]

[vanHorck]

ahhhh I can feel a long bashing thread coming up.... misrepresentations, lies, anger, cries, reminds me of a scottish club and inhouse flying school falling out less than a year ago.....

Carry on, there s not much happening in the news anyway, I love all of you!
:ok::ok::ok::ok::ok::ok::ok:

[Fuji Abound]

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.

EASA's terms of reference.

One wonders why they even contemplated developing a similiar rating if it was impossible. Nore carefully no mention of approach limitations. Perhaps they didnt know what they were doing when they drafted their own terms of reference or perhaps they have chosen to ignore their terms of reference.


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.



This is what our Government said with the full knowledge of the CAA and the DTi. No mention there that the priviliges on the IMC rating holder could not be protected.

421C - it is a very dangerous game making statements such as these (and I could refer you to quite a few more) if you were never able to carry them out.

Anyway as I have said before discussion is a complete waste of time - you dont know what you are talking about anymore than most other people - time will tell and the battle lines will be drawn. If there is the will to resist these changes then indeed the changes will be resisted but it is not yet the time. :)

['Chuffer' Dandridge]

I always thought that the PPL/IR Europe organisation were some kind of elitist group who looked down their noses at IMC holders.. Looks like i were right!

Anyone fancy forming an elitist PPL/Night rating group?:E

[mm_flynn]

I will say it again - Tell any European PPL what an IMCR is, and then ask them whether they think its a good idea, and you will get a resounding "YES, wish we had that!!" in response.

Of course PPLs think it is a good idea (and certainly in the UK it is a better idea than just flying around in IMC with no training - which was what happened before the IMCr!). BUT - none of your National CAAs have in the past 27 years shown the slightest interest in implementing their own IMCr (which they were totally at liberty to do). It can hardly be a surprise then when the National CAAs get aggregated into EASA they still have no interest in implementing an IMCr.


Blathering on forums, Number 10 petitions, writing to FCL.008, dark threats, etc. are going to wind up with the IMCr holders being left behind. Only realistic lobbying of the key decision makers is going to achieve the objective of retaining all of the current privileges of the IMCr.

You guys need to choose your lobbying point and lean heavily on the CAA and Mr Sivel and/or whoever else is critical to making a decision - you need to give them a 'decidable option' - otherwise you will be left in the same lurch the UK government always leaves people in with a 'We tried really hard but sadly couldn't reach agreement...' as they sell you out.

PS - no one is 'holding their noses' up at IMCr holders - but the IMCr holders need to fight their battle not hope some Euro committee will save them!!

Until this weekend I thought AOPA UK were leading that battle - based on the magazine article they appear to have been leading from an armchair.

[Timothy]

Jim's own perspective may be read here (http://www.pplir.org/index.php?option=com_content&task=view&id=477).

[BEagle]

I see he talks about all the negative rubbish to be found on PPRuNe

He really knows how to seek support for his 'EIR' outside the narrow confines of the PPL/IR group.....sorry, PPL/IR 'Europe' as they now are.

Incidentally, do tell him his PPL facts are years out of date.

Still, he does at least say that it is 'a personal view'......

[421C]

it is a very dangerous game making statements such as these (and I could refer you to quite a few more) if you were never able to carry them outNo. These statements are quite harmless. They commit to nothing. The "dangerous game" is the one you are playing, which, through some combination of naivety and/or optimism, is to clutch at any straw and convince yourself that someone has committed to "saving the IMCr".

some of the group experts were in favor to develop a similar rating as the UK national IMC rating What do you extract from that, other than some people thought it was a good idea? Didn't the AOPA UK representative on MDM032 present a proposal for the IMCr and have it firmly rejected by that group? So the minority views of "some group experts" did not prevail.

This is what our Government said with the full knowledge of the CAA and the DTi. No mention there that the priviliges on the IMC rating holder could not be protected.And no mention that they would, either. It simply is a loose reference to the FCL008 ToR's.

EASA has agreed to establish a rulemaking group to consider proposals for a similar rating at the European levelThat is the UK government wording, and not the wording of the EASA ToRs. It depends on what you interpret by "similar" and its usage here is perhaps misleading. Why do you need to look to some paragraph from the government on FCL008's ToRs, when they have been published in full in the public domain for a year now and the same point (FCL008 is not mandated to save the IMCr) has been repeated endlessly to you. How do you think this is helping the IMCr cause?
If the UK government believed that FCL008 was tasked with saving the IMCr, then no doubt it's own representative on FCL008, from the UK CAA, would have filed a minority report to this effect and objected to any breach in the terms of reference. Why don't you ask them, since you are relying on this government paragraph?

Anyway as I have said before discussion is a complete waste of timeIf you think the discussion is a waste of time, then take your own advice and stop posting on the subject. But if you post, I will reply when and if it takes my fancy.

- you dont know what you are talking about anymore than most other people I don't claim to be any more or less informed or authoritative than any other poster on PPRUNE, which is an informal discussion forum and not some international aviation court room.

[Fuji Abound]

421C

You raise some very good points.

Timothy

Thank you for that link.

We shall just have to wait and see.

[AdamFrisch]

The Euro-skepticism and downright hatred in the UK towards anything beyond its own shores is frightening at times (unless that someone happens to be a cheap Pole doing your house up for next to nothing or sweeping the floors at the local NHS ruin, that is - then it's OK).

What is the problem? An EIR is a nice halfway step towards a IR where all the hours count should you want to upgrade at some point. It's also something that's easily obtainable, can be done at any flight school and relatively cheap. And when they day comes when you feel you need it, you do a bit more training and upgrade to an IR. What's not to like?

Oh, the IMC, yes. Well, that will get grandfathered in somehow, of course. It's obviously not just going to be rendered invalid overnight. It might in a worst case scenario just be a grandfathered in to a EIR - and although that's slightly unfair perhaps, grandfathering you in to a full IR would simply be unfair to everyone else with a real IR as you don't have the training required. At best, it stays a national rating that you can use just like you do today. I'm amazed at the arrogance and scorn lavished upon our fellow Europeans for not immediately falling on their knees and adopting the beloved UK anomaly, the IMC.

Once all this EASA stuff is integrated across Europe in two years, then it will be a marvelous thing. How quickly we forget - I remind you what a royal pain in the a** it was to fly anywhere else but in your own country just less than 5-10 years ago. Not to mention the costs and time professional crews had to endure if they ever wanted to work anywhere else.

Despite the imperial tendencies and transatlantic flirtings, last time I checked the UK was in Europe. You don't have to love it all, but at least stop hating it all at all times.

[Pat Malone]

For the avoidance of doubt, here is the full text of the article in General Aviation magazine referred to above.


The battle to save the IMC rating has entered a new phase, with the EASA working group charged with examining the issue having dodged its responsibilities while seeking to hammer another nail in the rating’s coffin. Despite its terms of reference the group, called FCL-008, has wound up without addressing the issue of the IMC rating and now believes it to be a dead duck. AOPA maintains the rating is a lifesaving qualification which is in large measure responsible for the UK’s excellent GA safety record, despite Britain’s notoriously changeable weather, and must be preserved.
AOPA has arranged an urgent meeting with EASA’s Deputy Head of Rulemaking Eric Sivel on December 2nd to ensure there are no further misconceptions about the rating, and has begun a programme of lobbying in Europe and the UK to support its retention. In particular, it is pointing out how FCL-008 failed in the task it was set, and is asking EASA and the CAA to clear away the confusion that surrounds the issue of whether a European country can create a one-state rating and attach it to an EASA licence, which would allow the CAA to maintain the IMC rating in the UK. EASA personnel have given conflicting advice on this, and the CAA is equivocal, but it’s become too important to allow such fudging.
Some 25,000 IMC ratings have been achieved, and 23,000 IMC holders still had valid medicals as of 2008. The CAA says that in 27 years, only one IMC rating holder has been killed in actual IMC. AOPA has received unqualified support for its campaign to save the IMC rating from the British Air Line Pilots Association, the Guild of Air Pilots and Air Navigators, the RAF Flying Clubs Association and other organisations, but non-UK delegates at FCL-008 have gained the impression that Britain does not care about it because the IMC rating has been misleadingly portrayed to them.
The Europeans have mistakenly gained the impression that the IMC rating is equivalent to an Instrument Rating with one fifth of the training, that few people in the UK support it, and that British pilots will prefer a proposed ‘En Route Instrument Rating’ for which a course of theoretical exams must be passed before the holder is allowed to fly in the cruise in IMC, with no approach and landing training or privileges – a travesty of what the IMC rating seeks to do.
FCL-008’s terms of reference were headed ‘Qualifications for Flying in Instrument Meteorological Conditions’ and included under section 3, Objectives: ‘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.’
However, in a letter seeking explaining his position to AOPA, delegate Jim Thorpe of Europe Air Sports claimed it was never tasked to look at the IMC rating. “The terms of reference of FCL 008 have always been public,” wrote Mr Thorpe, chairman of PPL-IR. “They might be summarised as proposing a more practical and accessible system for private pilots to fly IFR in Europe. While they are informed by the UK IMC experience it was never within the group’s remit to consider the IMC within the UK.” This runs directly counter to the stated understanding of Eric Sivel, EASA’s Deputy Head of Rulemaking, who told IAOPA in an open meeting in October that FCL-008 had been tasked to look at the IMC rating situation and the proposal for a simplified IR, and if it did not produce a workable solution to the IMC problem, then it had failed in its purpose.
In his letter, Mr Thorpe goes on to make a number of assertions about the IMC rating which, while highly dubious, have become the accepted view at FCL-008.
*“the IMC rating essentially offers the same privileges as an IR on the basis of 20% of the training.”
*“the position where its privileges are essentially the same as a full IR but the CAA has consistently advised pilots not to use the privileges they have themselves granted is ludicrous”
*“most of the arguments in (the IMC rating’s) favour, such as its role in enhancing safety and the unique nature of UK weather cannot be credibly substantiated by the facts.”

Antipathy
The background to the setting up of the FCL-008 Working Group is worth reviewing. Those invited to take part were Morten Keller of the Danish CAA, Mike Dobson of the UK CAA, Mathieu Burgers of the Netherlands CAA, Raimund Neuhold of an association called IAAPS, Jean-Benoit Toulouse of the European Cockpit Association, Jim Thorpe of Europe Air Sports (and PPL-IR) Andrew Miller of Europe Air Sports (and British Gliding Association) Pierre Podeur of Europe Air Sports, and Dr Michael Erb of AOPA Germany. The secretary was Matthias Borgmeier of EASA.
AOPA UK was not informed until after the places had been filled. Before FCL-008’s first meeting, Mr Thorpe asked for a meeting with Martin Robinson of AOPA UK to make sure he did not object to Europe Air Sports, an umbrella group of aviation organisations, having so many representatives on FCL-008 while AOPA UK had none and IAOPA only one. At that meeting he gave no indication of any antipathy to the IMC rating. Martin Robinson told him AOPA UK would not object to the number of Europe Air Sports people on the group (which would have been a fruitless exercise anyway), but reminded him that the IMC rating was vital to the UK and there should be no move to undermine it. AOPA UK, he added, was not seeking to foist the IMC rating on the rest of Europe, as some had claimed, but it was extremely concerned to retain it, or else adopt a rating with almost identical privileges, in Britain.
In the event, the only person to try to get a serious discussion of the IMC rating going was Dr Michael Erb of AOPA Germany who, briefed by AOPA UK, tried to have the matter reopened on several occasions. He got no support from the UK delegates, and it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates.
Mr Thorpe maintains that despite the fact that AOPA UK did not have a seat on FCL-008, responsibility for supporting the IMC rating fell solely to AOPA and was nothing to do with him. In his letter he says. “From the start it has been AOPA’s responsibility to lobby for the retention of the IMC.” But where else was the rating officially under discussion?
He goes on to attack the IMC rating in uncompromising terms. “I believe that most of the arguments in its favour such as its role in enhancing safety and the unique nature of UK weather cannot be credibly substantiated by the facts. Nevertheless pilots and flying schools like the rating and it can equally be said that negative impacts are also anecdotal. The position where its privileges are essentially the same as a full IR but the CAA has consistently advised pilots not to use the privileges they have themselves granted is ludicrous. It is in the great British tradition of daft compromises. It has been cobbled together over time ending with something that no one would ever have designed from first principals (sic) but which somehow works.”

Prejudice
Martin Robinson says: “The idea that the privileges of the IMC rating are essentially the same as those of the IR is so wide of the mark that IMC rating holders must be aghast. Many of those things that have been presented to FCL-008 as ‘facts’ are nothing more than prejudices masquerading as truth; there’s been no research, no intellectual rigour, nothing more than assumption piled on presumption, which would be comical if it wasn’t for the fact that consigning the IMC rating to history would put pilots in danger. It cannot be allowed to happen.
“When Mr Thorpe says claims that the IMC rating improves safety ‘are not supported by the facts’, what facts is he talking about? If he would like to meet some pilots who owe their lives to the rating, I can provide them. The purpose of the IMC rating, to save pilots who inadvertently fly into IMC by helping them keep control of their aircraft and returning them safely to the ground, has been utterly misrepresented to FCL-008 and to Europe.
“The notion that no-one in Europe supports the IMC rating is also misplaced. I believe it stems from German opposition to the Instrument Weather Rating proposed under the JAA, and has become a truism. Many NAAs and pilot groups around Europe would welcome an IMC equivalent – they’ve simply never been asked.
“Furthermore, given that under EC airspace proposals it would be possible for states to decide whether an IMC rating was useable in their own airspace, it seems that FCL-008’s decision to dismiss it out of hand is particularly unfortunate. It would have been far better to present the truth and try to change some minds. Some opposition to the IMC rating was expected, but we didn’t expect to be hung out to dry by our own side.
“This issue needs to be put in context. EASA has publicly stated its commitment to banish the N-register from Europe, and one of the major reasons so many people fly N-reg aircraft on FAA licences is that the FAA IR is far more sensible and achievable than the European equivalent. Change needs to come in pursuit of EASA’s stated aim. At the same time, noisy opposition to the IMC rating has come from the European Cockpit Association and some NAAs. It would have been an act of political courage for EASA to go against it – far better to create a Working Group that would kill off the rating and carry the can, then EASA could shrug its shoulders and say it did its best.
“The question now is exactly how to save the IMC rating. Our first step is to sit down with Eric Sivel early in December to clear up any misconceptions he may have about the UK position on the rating and to point up the fact that FCL-008 has not done its job. At the same time, AOPA is working at the European Parliament and the European Commission to marshal support for the rating, and we have already had positive responses from the most senior figures in the EC’s transport department and a number of MEPs. In particular, the CAA needs to stand up and be counted. It’s no use trying to be all things to all men – that’s one of EASA’s problems. Were it not for EASA, the CAA would not be sitting down and discussing the need to kill the IMC rating – why do they acquiesce to this? We need an unqualified expression of support from the CAA, and I would also like to ask Europe Air Sports whether their delegate actually speaks for them.
“The FCL-008 proposals will be transformed by EASA into a Notice of Proposed Amendment, at which point consultation will be invited and we will be ready. AOPA’s postbag in support of the IMC rating is bigger than any it has had before, and at the correct time we will mobilise that support in a targeted letter-writing campaign. I believe that despite the obstacles it is possible to reverse the situation and I will expend any effort to do so.”

[wsmempson]

Timothy,

Thanks for the link. Very illuminating to hear first hand what Jim Thorpe actually thinks, rather than hearsay.

It does seem incredible that a representitive of PPL/IR, a minority interest organisation (328 british members), who is so brazenly hostile to the future of a rating which has served uk pilots so well, can pop up in such an important commitee and purport to represent the interests of British IMCR holders. As a member of AOPA, I am disappointed by their choice of representitive for this commitee and am curious as to why the opinion of the membership was not consulted at an early stage?

I particularly enjoyed Mr. Thorpes comments about how the unique european ratings were all so understandable (mountain ratings, et al) and how there could be no logical argument for the IMC on the grounds of there being unique and changeable weather patterns in the UK as a result of our maritime climate and being a small northern european island, as the weather in germany and sweden is just the same. I shall leave it to some of the professional met folk on this forum to explain why this point of view is incorrect - suffice to say that I think that Mr. Thorpe needs to re-sit his met exams...

I expect that next he'll be telling us that the Brevet de Bas is a terrific idea, and that VFR-on-top privilage allowed to a French vfr PPL is great because in europe, there will always be a hole in the cloud at the end of the journey to descend through.

The net result of this promises to be that IMCR holders will have a useful rating taken away and, if we're good little boys, we may be allowed to sit the full IR theoretical knowledge exams, submit to retraining and re-sit a flight test in order to gain an EIR - which will be markedly inferior and less useful than the rating we already enjoy.

I predict that two things will happen as a result of this;

1. Yet another group of pilots and aircraft from the european register to the American register

2. That pilots will simply fly IFR without any rating, in the absence of an attainable, useful, european rating and people will be die as a result.

What a shame.

[Mike Cross]

As a member of AOPA, I am disappointed by their choice of representitive for this commitee and am curious as to why the opinion of the membership was not consulted at an early stage?

AOPA UK did not have a seat on the working group and was therefore not in a position to nominate a representative. Neither did PPL/IR. The seats, as is normal with EASA, were allocated to European representative bodies. AOPA UK were therefore represented by Dr Michael Erb of IAOPA Europe. Jim Thorpe represented Europe Air Sports.

In the event, the only person to try to get a serious discussion of the IMC rating going was Dr Michael Erb of AOPA Germany who, briefed by AOPA UK, tried to have the matter reopened on several occasions. He got no support from the UK delegates, and it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates.


The pupose of the working group was to come up with something that can eventually be translated into a NPA, which will go out to public consultation. No doubt the response to that consultation from UK IMCR holders will highlight the working group's failure to adequately seek or consider their views.

[cessnapete]

I find the politics surrounding this debate criminal. We are talking about promoting flight safety and perhaps saving peoples lives, and all we are hearing are various European bodies trying to outdo each other in ''my way is best'' arguments.
Surely the UK IMC rating can remain intact in the UK by CAA approved grandfather rights,it is a lifesving qualification and hopefully will lead some rating holders to go on to the full IR.

The crux of the problem is, the UK IR having far too much technical content fopr the PPL user. We have a perfectly good template for change in the FAA IR model where the exam content is tailored to the knowledge needed, but the flying test remains the same as the professional qualification. If the statistics are read in the USA we do not find scores of USA IR holders falling out of the skies.
Holding both a JAA and FAA rating I found the FAA test superior and far more practical, ie no more interminable NDB holds and letdowns and proper testing in modern GPS procedures. ( I believe the CAA still do not have examiners who can test GPS approaches in an Initial IR Test)
We live in a fantasy world where I can fly happily around Europe in the Airways with my N reg aircraft with my FAA IR, But if I get a paint brush and change the N for a G the same aircraft with the same avionics is now banned from IFR in Europe.

The attitude of officialdom in the UK also needs pushing into the 20th. Century. I wrote a year or so ago to the CAA SRG department, asking the reason for their continued aversion to an FAA style IR for PPL holders. In his reply, the CAA Flight Operations Capt, stated as one of his reasons, that the FAA rating was not suitable for European weather conditions! I received no reply when I asked him why the United Airlines B777 Capt was therefore allowed to fly into UK airspace with the selfsame FAA IR.
It is incredible that EASA fiddle with politics when peoples safety is at stake. Common sense and air safety should come first.

[Fuji Abound]

No doubt the response to that consultation from UK IMCR holders will highlight the working group's failure to adequately seek or consider their views.


Well said Mike - I have no doubt.

Jim Thorpe

Having read very carefully Mr Thorpe's explanation I have seldom seen a more confused and muddled paper which is so riddled with inaccuracy and misconception. Is it any wonder FCL008 were so poorly informed about the IMC rating. I suspect that Mr Thorpe has had a very different agenda all along. The British member's of PPLIR should call for his immedaite resignation.

As I said before, presumably lead by Mr Thorpe, FCL008 have clearly completely ignored their own terms of reference. That in itself is an appalling state of affairs and unfortunately will bring in to question whether the committee has acted unconstitutionally.

[papasmurf]

If the proposed EIR is accepted and (with additional training) pilots will be allowed to fly airways, out of sight of the surface, to find a hole in the cloud at the destination airfield to land VFR, no doubt French pilots will be grandfathered an EIR as they enjoy all these privileges already on a basic VFR PPL??

To quote IAOPA’s last e-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 may not have been tasked with saving the IMCr but they darn well need to come up with an acceptable solution.

As seemingly bona fide reports imply that Mr Thorpe is not accurately representing the UK support for the IMCr, I will, for one, be sending a letter to EASA’s Deputy Head of Rulemaking Eric Sivel today.

Personally, even though Mr Thorpe says “claims that the IMC rating improves safety ‘are not supported by the facts’ ”, I can think of several accidents where an IMCr might have avoided fatalities. How many pilots will die because Mr Thorpe thought “responsibility for supporting the IMC rating fell solely to AOPA and was nothing to do with him”??

[IO540]

no doubt French pilots will be grandfathered an EIR as they enjoy all these privileges already on a basic VFR PPL??

That's not a privilege of the French in particular. It is a lack of the UK CAA requirement to be in sight of the surface.

Most of the world can fly VFR above a solid overcast.

[Fuji Abound]

"An urgent meeting has been arranged between AOPA UK and EASA's Deputy Head of Rulemaking Eric Sivel on December 2 to discuss, inter alia, the UK's IMC Rating, which has been totally misrepresented to the rest of Europe by vested interests pursuing their own imperatives. Some 25,000 UK pilots have taken the IMC Rating in the last 27 years. It is a 15-hour flying course which equips pilots to maintain control if they accidentally enter IMC and to get their aircraft safely back onto the ground. It confers no rights to file IFR, no extra access to airspace, and no additional privileges beyond the PPL apart from absolving the holder from the UK requirement to remain in sight of the ground. "

Well worth repeating from IAOPA - my bold.

[bookworm]

Worth repeating only because it's utter rubbish.

The IMC rating confers the right to file IFR in class D and E airspace (as well as classes F and G, which, on a technicality, is also possible for PPLs without an instrument qualification within the UK), the right to fly (and to plan to fly) in cloud.

If AOPA UK wishes to introduce to Europe a rating (based on a 15 hour course of IF) whose only privilege is to "absolve the holder from the UK requirement to remain in sight of the surface" then they should go ahead. I doubt they'll get many takers though, given that with a 25 hour IF course you'll be able to get an IR.

[marioair]

Can someone please explain to me something, minus all the mud-slinging. Under the proposed EIR:
1.) At the time of takeoff your METAR at departure and TAF at destination look VMC so you're legal
2.) Enroute you hit IMC and using your swanky EIR skills manage to continue.
3.) The weather takes a turn for the worse and your destination and alternate are under cloud but above the IMC mimuma. With your old IMCr your would have had the skills to peform and ILS etc.....
.....What do you do with the EIR???? Make up your let down OCAS without an approach aid?? Decsend into VMC outside the ATZ and maybe under the range of radar coverage???

[mm_flynn]

Fuji - I am totally lost now.

Are you saying the bold is what should be defended, which is a bit bizare as the elimination of ISOS will just happen under EASA and no one will complain or restrict a training scheme that adds no privileges. Or are you making the point that IAOPA and possibly AOPA UK have lost a grip.

[Cows getting bigger]

I think he is making the point that the stuff in bold is absolute claptrap. It is amazing that an organisation which supposedly understands and represents the views of UK GA has completely and utterly got it wrong. Someone in a position of influence should point out this very significant factual inaccuracy. If this statement reflects the level of understanding that appeared at FCL.008, then the whole lot need to hang their head in shame.

Pointed question - what is AOPA UK doing to amend this IAOPA statement? Isn't Martin Robinson the link? :ugh:

[tmmorris]

I'm a bit bemused by Jim Thorpe's paragraph on grandfather rights. He only considers two possibilities - that an IMC rating holder might be allowed to take the full IR TK exams and end up with just an EIR; or that an IMC rating holder would be given a full IR with no further requirements. The former is a rip-off; the latter is clearly a paper tiger, as no-one has seriously suggested it.

It has always seemed to me that one of the biggest problems for IMCR holders wanting to go for an IR is that they receive no credit for IMC flight they have already undertaken, either the 15+ hours to get the IMCR, or subsequent flights in IMC - even tests undertaken with an examiner. If I could be credited with 15 hours for the IMCR course, say 6 hours for the three renewals I've done since, plus perhaps 10 hours max for other IMC time logged, I'd be more than half way to the requirements for the IR. If you added into that a more sensible TK exam with self-study a la FAA IR, I'd call that fair and I might actually afford it.

It's not that I don't want an IR. It's just been out of my reach and up to now an IMCR isn't even a stepping stone.

Tim

[Fuji Abound]

I think he is making the point that the stuff in bold is absolute claptrap.


Yes


Jim Thorpe

I am dismayed with the way Mr Thorpe has behaved for a number of reasons.

Firstly, he comments in his "write up" on PPL/IR that these are his personal views. It is well know that Mr Thorpe is the protagonist of the EIR. He is also a member of FCL008. He is not entitled to personal views or at least not that he should publically air at this stage in the process.

Secondly, either the EIR has been so poorly thought out that he cannot setout in his "write up" how he believes it will work which beggars belief, or he already knows the rating will be worthless other than as a stepping stone to a full IR in which case he should be honest enough to say so.

Thirdly, if you consider the whole "write up" not only does it contain numerous inaccuracies but is terribly biased.

All together posting this on PPL/IR was very badly conceived and I would have thought some of the more responsible members of that organisation (Bookworm as one example comes to mind) would have cautioned him not to go to press.

[mm_flynn]

Fuji,

I am even more mystified.

Yes

Jim Thorpe

You can't seriously imply that Jim is writing the bold for IAPOA. That piece of clap trap is virtually word for word from Pat's rant in GA.


Secondly, either the EIR has been so poorly thought out that he cannot setout in his "write up" how he believes it will work which beggars belief, or he already knows the rating will be worthless other than as a stepping stone to a full IR in which case he should be honest enough to say so.
The EIR was very clearly not proposed as a replacement for the IMCr but as a stepping stone to an IR, Jim's article makes very clear FCL.008 could not come up with a set of rules that would meet the constraints they were given, continue the mini-IR capabilities of the IMCr in the UK and make sense/be accepted in the rest of Europe. Jim has honestly said so, in print. You can agree or disagree with the outcome and his views, but attributing false statements and insinuating he has failed to be honest is ridiculous.


CGB - The clap trap comes from GA magazine, not from the people on FCL.008 - who clearly did understand the current privileges of the IMCr and how those might map into a European rating - as compared to the author of the quoted text.

tmmorris - Jim is suggesting that most IMCr holders who use their IMC in anger should with nil or modest training pass the IR flight test and therefore should be allowed to do so. He has a view (and I have no personal basis to agree or disagree) that the IMCr TK requirement is a bit light for world wide operations and there should be a verification that people have extended their knowledge to that sensibly required for IFR flight by way of the TK test. For people in your situation, this seems a fantastic opportunity, all your time counts, for very little extra work you get a full IR and can substantially expand your geographic scope.

[Fuji Abound]

You can't seriously imply that Jim is writing the bold for IAPOA.



No, I was referring to his write up on PPL/IR.



The EIR was very clearly not proposed as a replacement for the IMCr



In which case he should have made that bald statement rather that produce a totally confused write up which hops from IR lite to IMCr to EIR and leaves most people (as has become apparent form these threads) with absolutely no idea what is going on, and even worse, no confidence in FCL008, Mr Thorpe or EASA.


that the IMCr TK requirement is a bit light for world wide operations


Which is particularly worrying because to me it indicates he is completely out of touch with the needs of the "average" pilot.


Which leads me in to a post I wanted to make directed at Bookworm and others.


I have said it before, but it is perhaps worth repeating.


Please don’t take exception, because it may well be me that is out of touch, but I think you and some others may have little understanding of what the vast majority of pilots want.


Let’s start with what they don’t want.


They don’t want to fly half way across Europe. They don’t want to fly high performance twins. They don’t want to fly hard IFR in the extremes of weather. They don’t want to breathe oxygen for hours on end. Most of the time they don’t want to climb into the higher airways operating on the edge of the performance of most light singles. What they don’t want most of all is weeks at Oxford which they can ill afford.

I could tell you why they don’t want it, but we will leave that for another day.


So what do they want?


They want to undertake short sectors – a couple of hours perhaps to see their mates, meeting up for a coffee, that sort of thing. They want to go from Lydd to somewhere in the Midlands in the knowledge that when they go they can get above a pesky 1,000 foot overcast and cruise safely in better weather at 3,000 feet. They want to feel that when they come back if the base is 1,000 foot at Lyd they can potter down the G/S rather than scud run into their home field.


I think pilots in France and Germany and Holland largely want the same.


The EIR will not result in hoards of pilots routing airways to the south of France at FL100. Most are far happier going sleazy jet, many cant afford it in light singles and if they can they don’t have access to an aircraft they can take away for a week. Many have family and the family don’t want a weeks flying holiday wondering if they can get back to Blighty even with an EIR.


In short the EIR is a solution to a problem that doesn’t exist.


Some do want a more accessible IR and if it is sufficiently accessible it may even be a solution to the debate we are having.


Please don’t loose site of what I believe most want and, indeed need, just because you want something else.

[nakuru flyer]

Completely agree. I work at a large Club in West London where a good number of new PPLs go on to the IMCr or AOPA Radio Navigation Certificate. THis gives new pilots confidence as well as an increased level of skill. We have a weekly friday Fly Out regularly launching 6-8 aircraft. Most of these pilots are regularly using their IMC ratings often carrying out Instrument appraoches at their destination.On longer continental flyouts the skills afforded by this rating prove invaluable.Most PPLs dont need an IR but they do need the IMCr . Dont throw the baby out with the bath water!:ok:

[bookworm]

All together posting this on PPL/IR was very badly conceived and I would have thought some of the more responsible members of that organisation (Bookworm as one example comes to mind) would have cautioned him not to go to press.

The only caution I would have offered anyone was to those of you who fired up a distasteful and personal attack on him in the first place, based on misinformation. Now, instead of a constructive debate on FCL.008's proposals, we seem to have battle lines being drawn up and trenches being dug. I don't see how that can possibly be in the interests of GA instrument flying in Europe.

[Pace]

Fuji

I cannot disagree with a lot of your comments but I can with some.

The IMCR is I do not believe used in anger by the majority of IMCR holders.

Many got the IMCR as a safeguard for VFR flying and that is where the safety attributes of the IMCR lie.

Some do use it in anger as an OCAS mini IR but with pilots I know they tend to be ones who have added to their skills practically over time and who tend to be much more experienced.

Apart from maybe once a year on a holiday or adventure most who dont use their PPL for Business probably do pay for their hour fix every couple of weeks with a short trip in the UK.

I say this with sadness but I predicted things going this way a year ago.

The IMCR as a European rating is a non starter. Forget it as it wont happen.
You may get some allowance where the IMCR can be kept with the UK on some sort of special needs basis.

The IMCR is talked of as if it is something static to be saved. The IMCR is purely a minimal set of instrument flying requirements which theoretically could have been an hour instrument training called the IMCR to a full IR called the IMCR with anything in between called the IMCR!!! IE IMCR is nothing more than a name.

There is a bigger opportunity here of a more easely attainable IR not a lesser quality IR any more than the FAA IR can statistically be shown to be a lesser quality IR than the European Variety.

Use the loss of the IMCR as levarage for some Grandfather rights to more easely getting a PPL IR and we have a possibility? Call that an IMCR and you would be happy???

Pace

[IO540]

The IMCR is I do not believe used in anger by the majority of IMCR holders.I think that is true, but same is true of the IR - except for commercial pilots flying daily.

When I fly from here to say Spain, I use about 1% of the IR theory, 1% of the instrument skills, etc. 99% of IFR flight is in sunshine, on autopilot... Half an hour before you get there, you dig out the STARs etc... any monkey could do that.

With a well equipped plane, the need for currency is much lower than with a poorly equipped one.

I still don't believe the IMCR will be killed off in 2012 - the safety implications would be pretty serious.

The IMCR is purely a minimal set of instrument flying requirements which theoretically could have been an hour instrument training called the IMCR to a full IR called the IMCR with anything in between called the IMCR!!! IE IMCR is nothing more than a name.

The IMCR is a 15hr course, normally taking about 20-25. It covers all the stuff one needs to fly fully IFR, except sids/stars and other (trivial) airways concepts.

[Pace]

When I fly from here to say Spain, I use about 1% of the IR theory, 1% of the instrument skills, etc. 99% of IFR flight is in sunshine, on autopilot... Half an hour before you get there, you dig out the STARs etc... any monkey could do that.


10540 :hmm:

You must be very selective on your weather because thats nothing like my IFR flying.

The IMCR IS Minimal flying hours and flying to large tolerances my point there is that the IMCR is just a name. Dont loose that fact. You could stiffen the requirements for the IMCR overnight and still call it the IMCR or you could drop the requiremets for the IMCR and still call it the IMCR.

Go for a full IR more easely achievable and call that the IMCR then we can all say the IMCR has been saved like the whale.

Pace

[IO540]

Go for a full IR more easely achievable and call that the IMCR then we can all say the IMCR has been saved like the whale.


Well yes, obviously :)

So, let's see what you would need to achieve...

1) Doable in one's local PPL school

2) Not costing £10,000

3) dammit I am not typing that list all over again :)

Politically, it isn't going to happen.

The best outcome will be the existing IMCR to remain (under some local-airspace political fudge), and possibly a simpler ICAO IR designed to entice all the FAA IR holders to move over to it.

As regards my selection of flying weather: I don't go if the enroute section cannot be flown in VMC - up to FL200. Plus some other considerations.

[ScouseFlyer]

Well said Fuji.

I have been watching this thread as it has developed and become more and more amazed at some of the drivel being espoused by many who clearly have agendas of some sort or other.The scenario you outline is certainly my experience of the the sort of use made of the IMCR by PPL's that I come across week in week out and is certainly the way I use it.

Its to be hoped that the opportunity for some common sense to prevail has not been lost and we don't end up in a situation where IMHO safety could be seriously compromised as a result of these half baked proposals which I suspect are not wanted by the vast majority of PPL's but rather possibly by those who might see themselves at more of the "elite" end of the PPL spectrum.

SF

[robin]

So what is the problem?

Is it that those with deep pockets who have spent lots of wonga on an IR don't like to share the airspace with oiks with an IMC.

And from the years of evidence we have of IMC-equipped pilots, has there been an incident that can show it is inherently unsafe?

Being a low-end VFR pilot who can't even afford the IMC, I'd quite like to know what is going on. It does seem that there are some vested interests screwing up the debate here.

[S-Works]

I don't think anyone is claiming it is unsafe. It gets so little use in reality (apart from a few diehards flying well equipped aircraft) that it would be hard to prove it is unsafe. I phoned around the main GA IFR airfields this morning to get a view on light GA non airways IFR in the past week (training flights removed) and did not make it to 10.....

What I object to is the wild claims that it's loss will have tin raining on our heads. Those type of claims are just red top reporting.

Whats it's loss will mean is that pilots will not have a rating that enhances pilot ability, skill and confidence. However the solution to that is for AOPA to maintain it as a certificate rather than a licence rating. The course could still be taught and pilots will have the approach and instrument experience to get out of trouble. Those who want to go serious IFR touring then have the option of doing the IR and going touring. The UK is getting ever smaller in terms of available IAP's anyway.

[ScouseFlyer]

Robin
Not sure it is entirely that but the risk is that potentially it is only those with deep pockets that could afford the new proposals so that you and many people in similar circumstances potentially lose the opportunity to expand your experience and learn skills that will make you a safer pilot-because you can bet your bottom dollar if you can't afford the IMCR the new proposals are likely to be a lot more expensive.Have a look at the other thread on how erir may work to see what a nonsense it could become.

SF

[Brendan Navigator]

If what has been posted here is to be believed than only 17.4% of current IMC rating holders want to keep the rating enough to petition their local government.

This "Unique UK Weather" diminishes the credibility of those proposing the idea. How is the weather on one side of a land border different from that on the other side?


FCL-008’s terms of reference were headed ‘Qualifications for Flying in Instrument Meteorological Conditions’ and included under section 3, Objectives: ‘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.’



Quote from AOPA.

No where in the above is there any mention of retaining the UK IMC Rating.

The UK IMC rating was going to be looked at as was cloud flying by gliders and other cases where flight in IMC takes place without an IR.

Having reviewed the situation then there was a decision to be made - Is there a need to develop an additional European Rating to fly in IMC with less training, but also with limited privileges?

Clearly having completed the review they decided that the answer to the question was "Yes"

Now that they have decided "Yes" they have also published how they propose to do it.

That is a proposal. How about coming up with a proposal that will be not only bemore acceptable to the 17.4% of UK pilots (tiny percentage of European pilots) but also acceptable to the regulators.

The UK IMC rating may be 15 hours of a course but the actual IMC / simulated IMC time is very small. Contrary to what someone said earlier it does very little to prepare the pilot for IFR enroute flight and the enroute element is basically VFR enroute planning but above MSA and in IMC. There is no SID / STAR training despite the fact that in the UK, the privileges entitle the pilot to Depart on a SID, fly along an ATS route and compete a STAR with IAP at the destination.

Finally, look at the many arguments on these pages about IMC Rating hoders minima. If the argument that they can use IR minima with a visibility restriction than any other European pilot will translate that into having privileges that they use their IR for - ergo, the UK IMC Rating gives a UK pilot the same privileges that French PPL-IR uses to fly IFR on the lower airways.

[Brendan Navigator]

With no IMC, rating more people will be killed chancing their arm in marginal weather, due to the lack of training.


Perhaps this says more about the attitude to safety than the perceived improvement in safety conferred by an IR or IMC Rating.

If it is winter time with the freezing level below the MSA, please explain how IMC flight in a non-deiced aircraft is going to be any less dangerous than flying below cloud.

I believe that in such a case the only safe option would be to remain on the ground.

Brendan.

[robin]

If what has been posted here is to be believed than only 17.4% of current IMC rating holders want to keep the rating enough to petition their local government.


Perhaps this is because we know that lobbying and petitioning our 'great and good' gets us nowhere.

Look at the responses to any consultation. It generally runs to the conclusion

"Thanks for writing in, but actually, we still think we're right so s*d you"

[Justiciar]

Whats it's loss will mean is that pilots will not have a rating that enhances pilot ability, skill and confidence. However the solution to that is for AOPA to maintain it as a certificate rather than a licence rating.

I quite agree with that and with Fuji's comments earlier. As I have said before, the trend towards, Permit, LSA, VLA (and other alphabet combinations) means there are likely to be fewer IFR equipped aircraft owned privately or in flight training schools. As a rating it will become less valuable, but as pure training it will remain an important enhancement to pilot skills. It is no different from doing an AOPA aerobatic course or mountain flying. All will improve your airmanship and handling, which is what it should be about.

I recently re read Alex Henshaw's Flight of the Mew Gull. In it he talks of spending hours training himself for "blind flying", sometimes using the new fangled gyro instruments. It was of course all about skills level and not about wanting to fly in IMC or IFR (which iI guess did not exist then).

[IO540]

The UK IMC rating may be 15 hours of a course but the actual IMC / simulated IMC time is very small. Contrary to what someone said earlier it does very little to prepare the pilot for IFR enroute flight Precisely what preparation would you say is needed for "enroute flight"?

Let me try to enlighten you. You turn the yoke so the AI is level, and you push it and pull it (with trimming for the more advanced pilots) to maintain altitude. You do what ATC tell you re headings/levels etc. You might be asked to hold (extremely rare) but I did holds in the IMCR so that's OK. You can fly any IAP too :)

The enroute element is basically VFR enroute planning but above MSA and in IMC. which is what obstacle-aware flight is, surely?

In airways flight, the obstacle clearance enroute is done by airway MEAs / ATC MVA etc. So that is easier. IMCR flight is done without this system/ATC support, which is why pilots are taught about MSA.

There is no SID / STAR training despite the fact that in the UK, the privileges entitle the pilot to Depart on a SID, fly along an ATS route and compete a STAR with IAP at the destination.Not in practice.

Firstly, there are hardly any (any??) SIDs in the UK whose join to the enroute waypoint is below Class A, so an IMCR holder could not usefully depart on one of these.

Secondly, if a SID is assigned, it will be handed out in the departure clearance, and if the filed flight plan was filed below Class A then the flight control officer (or whatever they are called here) isn't going to issue a SID. The only way to get a SID issued is if one files a legit Eurocontrol airways (which means generally FL100 plus) flight plan, which for an IMCR holder would be an illegal flight because there is almost no way to file a real IFPS flight plan without hitting Class A. I know of cases where this was done as an honest mistake and it caused havok, and I think measures have been implemented by London Control etc to avoid this - by them washing their hands of such low level flight plans. So no SID will be assigned to start with.

Thirdly, there is no STAR in the UK whose terminating (entry) point can be reached below Class A. Maybe something can be hacked which is flyable wholly in Class D but one would really have to work on it, but one would never be sure what IFPS/LTCC did with the flight plan, so the usual airways implied IFR clearance could not be assumed, so why bother filing such a contrived thing in the first place?

On the IMCR, one flies a mixture of CAS and OCAS, DCT as much as possible, and one joins to airports as directed by ATC.

[Brendan Navigator]

IO540,

It is possible in the UK with an IMC rating to legally fly an SID (in total) then along the enroute structure following an ATS route and then fly the full STAR, hold and approach. The departure is a busy UK international airport and the arrival is likewise. The flight is 100% within controlled airspace and is 100% legal.

Perhaps this demonstrates that people don't really know how outsiders see exactly how the IMC can actually be used in the UK and how it can result in a pilot attempting to do something that the rating entitles them to do but they have received absolutely no training in.

I think that is why everyone (outside the UK) looked at the UK-IMC rating and said straight away that the idea of copying it was a non-starter.

Rather than using incorrect information to try and retain a unique ( clearly misunderstood) rating that in other places gives effectively IR privileges to the average PPL. Why not put a bit more effort into getting a new rating that will acheive the aims and gat some from of bridging.

Anything else is doomed to failure I fear.

Brandan

[IO540]

It is possible in the UK with an IMC rating to legally fly an SID (in total) then along the enroute structure following an ATS route and then fly the full STAR, hold and approach. The departure is a busy UK international airport and the arrival is likewise. The flight is 100% within controlled airspace and is 100% legal.Could you post the whole route please? I am quite interested.

[FREDAcheck]

If what has been posted here is to be believed than only 17.4% of current IMC rating holders want to keep the rating enough to petition their local government.To get as many as 17.4% of any group to sign a Number 10 petition is unusual. I would say it demonstrates very strong support.

[FREDAcheck]

The Euro-skepticism and downright hatred in the UK towards anything beyond its own shores is frightening at timesAdam, if you think the pro-IMCR view is in some way xenophobic or anti-European then I think you may have misunderstood. This is not telling the rest of Europe they must do things our way, or mustn't do things some other way. It is asking very nicely if we can carry on doing what we've done for a long time, is liked here, probably increases safetey and (most important) doesn't cause any disadvantage to anyone else.

We'd like to recommend the IMCR to other countries, but failing that please can we keep it. What's anti-European about that?

Thinking that being "European" is about forcing everyone to do the same thing is like suggesting that we should drive on the right, that Bavarians should stop wearing Lederhosen, that the Irish should stop drinking Guinness... (enough national stereotypes)

[Brendan Navigator]

Could you post the whole route please? I am quite interested.


Sure. There are a number of examples using different airports but here is one;

EGPH. TLA SID then Direct to TRN then P600 to BLACA then the Standard routing via MAGEE to the approach procedure for EGAC.

-(FPL-GABCD-IG -C182/L -S/S -EGPH1200 -N0120F080 TLA DCT TRN P600 BLACA DCT MAGEE -EGAC0100 EGAA -OPR/PRIVATE)

Now how many people in the European regulatory system thinks that it is a good idea for a pilot with as little as 12 hours sole reference to instrument time to depart Edinburgh in a twin (having only doen the 12 hours training in a single) climb into the teeth of the Edinburgh and Glasgow arrivals to say FL160 and then route down the P600 to take up the hold at MAGEE - a procedure they have never been checked as being able to do and hold for 20 minutes because the weather at EGAC is below minima and then route back up the P600 to Glasgow.

Even taking the fact that a pilot can get an IMC rating in a single and then legally use it in a twin causes even the most ardent supporter some "concern".

[dont overfil]

Brendan,
Maybe just nit picking here but.........
You suggest that an IMC rating can be achieved with less than 15 hours actual IMC or simulated IMC. This was certainly not the case when I gained the rating. A MINIMUM of 10 minutes of time per flight was discounted for takeoff, landing plus any rest time.
When I obtained my multi rating the IMC renewal had to be done in a twin if I wished to use the privileges of multi IMC.
DO.

[Sick Squid]

I've only known personally three people who have died in light aircraft as recreational flyers since I started flying as a PPL in 1987. Each one of them was an IMC holder, in weather that they should never have been flying in, plus in one case, in an aircraft where the equipment let them down. Regardless, the one common factor is that without the rating they would have been on the ground.

The justification given above of using a rating to fly into what are basically icing conditions in a single-engine aircraft, shooting an ILS at the end to have coffee with friends is quite frankly ludicrous. As, to an extent, is the argument of using the rating as a get-out-of jail card if the weather deteriorates whilst in flight.

Perhaps the answer is a simple one, albeit in two parts. First part; raise the bar of the basic PPL to provide enhanced instrument flying skills to enable safe exit from IMC conditions, and re-test such skills annually. Second; a realisation that if you are not being paid to make the flight, which by definition you are not under the privileges of the PPL (and neither will it be for any defined business purpose of course,) then you have no right to place yourself or more importantly your passengers in any enhanced jeopardy.

Regardless of the fine-print differences between nations and tail-numbers, any rating that allows someone not fully trained to fly in instrument conditions in an aircraft not fully equipped for such is something that should be anathema. A basic skill-set to save your ass is fine, but allowing planning in such marginal weather for what is basically recreational flying is something that cannot withstand scrutiny.

Perhaps bringing the full IR within more peoples grasp would be a better goal? I am somewhat out of the Private Flying loop these days, but I still feel I would know 3 people still alive and enjoying their flying and their families today had their confidence not been artificially boosted above their competence.

Sorry if that sounds a bit arrogant coming from an airline pilot; it's not, it's a hard-earned viewpoint. Also, one I have espoused for many years now.

Squid

[IO540]

Now how many people in the European regulatory system thinks that it is a good idea for a pilot with as little as 12 hours sole reference to instrument time to depart Edinburgh in a twin (having only doen the 12 hours training in a single) climb into the teeth of the Edinburgh and Glasgow arrivals to say FL160 and then route down the P600 to take up the hold at MAGEE - a procedure they have never been checked as being able to do and hold for 20 minutes because the weather at EGAC is below minima and then route back up the P600 to Glasgow.OK I thought this might be in Scotland :)

But let's look at this

climb into the teeth of the Edinburgh and Glasgow arrivals Why is this a problem? The arrivals don't have "teeth". This traffic is all under radar control.

Also there is no way anybody is going to be competent in 12 hours. The average IMCR time is over 20. Mine was about 25.

to say FL160 That implies oxygen, or pressurisation, so we are looking at a more than average dedicated pilot. Not your PA28-140 type.

a procedure they have never been checked as being able to do and hold for 20 minutes I was taught to fly holds in the IMCR, and if you accept a well equipped aircraft type (as implied by the above mission profile) I don't see a problem.

You are assuming a mix of absolutely minimal experience, maximum mission complexity, worst case weather, most complex aircraft, flying into probably very expensive places. You just don't find this combination in the same place.

You could equally argue that a C150 could fly into Gatwick - which it absolutely can do, both VFR or IFR. That is a lot busier than anything in Scotland. So why don't they? Because it costs £500 to land there, and it would be too much bother even if it was free.

[FREDAcheck]

SS, I'm very sorry you have lost friends in this way. I understand that there have been very few accidents involving IMCR pilots in IMC, so I think you are unfortunate (to put it mildly) to know of three.
The justification given above of using a rating to fly into what are basically icing conditions in a single-engine aircraft, shooting an ILS at the end to have coffee with friends is quite frankly ludicrous.I agree, given you said "into what are basically icing conditions". Not a good idea.
...any rating that allows someone not fully trained to fly in instrument conditions in an aircraft not fully equipped for such is something that should be anathema...I don't have the knowledge to dispute what you say, but presumably the CAA think the IMCR training is sufficient? As I say, I understood that the accident record is pretty good. As a proportion of PPLs, IMCRs are said (I don't have the source) to have a lower rate of accidents in IMC than non-IMCR rated PPLs.

[ScouseFlyer]

SS
I would characterise your contribution as patronising rather than arrogant.Nowhere do I see in the post you refer to any indication that the poster was suggesting flying into icing conditions but rather climbing through cloud to vmc on top a situation allowed in many parts of the world on a basic PPL but interestingly not in the UK where to do so you require an IMCR!You seem to also hold the view that with the acquisition of an IMCR somehow basic airmanship is put to one side and common sense thrown out of the window.Whilst I am sorry you lost two friends apparently in situations that were beyond their capabilities in the situation they found themselves in maybe had they exercised good judgement and common sense they might be here today.That is not necessarily anything to do with holding an IMCR but rather a particular approach to flying.

SF

[Fuji Abound]

******* alias BoseX seeks to demonstrate that many IMCr trips could equally be done with an EIR. No one appears to know how you would descend through cloud between say 3,000 and 1,500 for a VFR approach other than via a made up let down with a hope and see cloud break. When the details of the EIR are eventually revealed we might know.

In the mean time the hypocrisy of Jim Thorpe should not be lost in going public with his “personal view” of the EIR in which he hints at the promise of a simplified IR, argues the EIR is a realistic replacement for the IMCr without providing any detail of how it will actually work and espouses the EIR as a stepping stone to a new IR of which he is silent on the detail.

It will come as no surprise to me when in due course a simplified IR does not emerge, the IMCr is abolished and the EIR proves to be a solution to a problem that never existed when Mr Thorpe and others point out that these were only his personal views.

Politicians, judges and many others learnt a very long time ago that when you hold an office you cannot afford to have personal views. In answer to your question Bookworm that is why I am so critical of Mr Thorpe’s article – I don’t need to know him, and can only judge by what I read. He has crossed a line that he should not have crossed. Moreover, we have been told here and elsewhere on many occasions that members of FCL008 sign a ND; either this was never true, Mr Thorpe has breached the ND or his article is with the consent of FCL008. In which ever event, unless I have missed an alternative, he is on very dangerous ground.

******* you were very clearly in favour of the IMCr and said so publically. I can refer you to your post if you wish. For the avoidance of doubt please would you now either confirm you stand by your earlier position or you have changed your position and if so please will you set out why? This is fundamental to your credibility.

You also refer to the IMCr survey. I assume when the results are announced you will also set out how and by who the questions were planned, how the results have been independently audited, and who has been asked to determine the statistical validity of the results. I made this point many months ago so you were clearly warned. I have to tell you that without this information the results will be meaningless and pointless; in a court of law they would not even be admissible evidence. I admire you for attempting a survey but hope you have not wasted your time and more to the point don’t damage the debate with data that is dreadfully misleading to suite your own agenda – whatever that might be?

Moreover AOPA have sadly not come out of this saga smelling of roses so far – I should remind everyone that the survey was conducted on behalf of AOPA and if and when the results are published it will be AOPA publishing the results (not ******* ) if I am not mistaken. I hope AOPA think very carefully about allowing these results to be published given my earlier comments unless they are absolutely certain they will stand critical scrutiny. If they are not certain AOPA will be damned for publishing whereas given the considerable delay that has already occurred at least they will not be damned for not publishing!

Finally I still don’t understand why some of you will not listen to the message that comes over loud and clear from this thread. It seems to be on the whole it is the private IR holder who will not do the listening. Pilots with IMCrs don’t want to fly on the whole in hard IFR conditions! Do you simply not understand that if the wind is 20 gusting 30 across the runway while that has nothing to do with whether or not they can see out of the window they don’t want to land in conditions which by definition are reasonably challenging. Have you never been to a typical GA airport on days such as this with good VFR and see how many people are flying – or should I say not. They don’t want on the whole to fly to minima and they don’t want to fly with oxygen in the airways. Do you not understand that for many short sectors an airway routing all other issues aside are a right pain in the arse? Do you not understand that they don’t want to breathe oxygen for hours on end and they don’t want to fly 10 times a week to the CIs to help maintain their income as a FI – they don’t need to, they have other jobs.

I think some of you are playing a very dangerous game judging what people want by what you want. The biggest mistake EASA made was in the composition of FCL008 – in their own terms of reference they state they are briefed with considering the IMCr and yet they don’t have a single representative on the committee with an IMCr. Surely IAOPA or Jim Thorpe’s lot could have managed between them to find someone with an IMCr?

(Also posted on the darker side but I feel worth posting here as well as the debates are similiar)

[Name removed - mods]

[Sick Squid]

Patronising? Fair enough, if you see it like that, but I think the two disciplines of visual flying and instrument flying should be completely and irrevocably separated, bar the the inclusion of a set of basic skills that are re-tested to allow a basically visual flyer to escape unforseen incursion into instrument conditions. I don't think it's patronising to have such an opinion otherwise I wouldn't have posted. I don't do patronising.

I feel that the allowing of planning into what are marginal conditions is way too much of a grey area, one that we in the UK have become accustomed to by the offering of such a rating, and perhaps it is time to realise that two completely different disciplines exist; that of Visual Flying in the associated Met conditions, and that of Instrument Flying in full IMC/Controlled Airspace in suitably equipped aircraft. As I implied above, would that all of the authorities around the World saw likewise, many do not at the moment.

As I also implied above, the opinion I give here is based upon a negative experience, and that in no way implies that everyone who holds such a rating will be going flying willy-nilly in marginal weather. But to someone who flies professionally, it seems an anachronism to have a middle-ground between the basic recreational licence and the full IFR licence and, importantly, to allow planning within the remit of that middle-ground rating.

It is indeed possible to climb on top through cloud avoiding the icing layer. Not always. Neither, in my experience, has the forecast top of the cloud layer regularly appeared as predicted, indeed yesterday it was 5000' out, which we had a laugh about as we were being bumped around waiting for clearance to climb from what should have been a clear level.

Sorry again if you feel it's patronising, it's just a heart-felt opinion based on my years and experience, one that as a Moderator (albeit not named on this part of the site) I thought several times before posting.

Squid

[David Roberts]

Rather than filling cyber space with a duplicated comment from me, please visit the 'other site' on the FCL.008 issue!

[mm_flynn]

... but rather climbing through cloud to vmc on top a situation allowed in many parts of the world on a basic PPL
Just for accuracy, there are many areas in the world that allow VFR in VMC without having the CAA resriciton of in sight of surface (i.e. VFR above a cloud deck).

HOWEVER, nowhere allows a PPL to climb through a cloud layer (i.e. operate in less than full VMC) without an IR, except the UK - which allows an IMCr to do this as well as an IR.

Additionally, unlike everywhere else, the UK allows a basic PPL to operate IFR in sub-VMC met conditions, in some airspaces - but not in 'proper' IMC.

[ScouseFlyer]

SS

Fair enough-I think we will just have to agree to disagreeiI just think its potentially aretrograde step to throw the baby out with the bath water.After all the proposed "solution" looks far worse to me in the context of PPL safety.

SS

[robin]

I feel that the allowing of planning into what are marginal conditions is way too much of a grey area, one that we in the UK have become accustomed to by the offering of such a rating

This is, by the way, not limited to IMCr holders.

[Utfart]

According to the documents available from EASA, dated October 3rd 2008, the objectives of the FCL.008 group are as follows:

"3. Objectives:
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. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR

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

Review the existing national requirements for cloud flying with sailplanes and assess the need for an additional European rating for sailplane pilots to fly in IMC

Take into account Air Traffic Control (ATC) requirements regarding Instrument Flight Rules (IFR) flights

Amend the proposed requirements for the instrument rating if necessary"

where does it say they are tasked with saving the UK IMCR? I don't care because I don't fly in the UK, but when I read this it says they will review the existing requirements to consider the development of a rating separate from the IR....period. I've never met Jim Thorpe either, but it seems silly to get the facts wrong while being so vicious.

[Fuji Abound]

Utfart

I fair point but here are some comments relevant to getting your facts straight:

I do not wish to disparage the efforts of many well meaning folk over this extended period. In a time of great change they did their best to adapt but the reality was that what emerged was not a finely crafted product carefully aligned to the needs and skills of pilots. In that great British tradition we ‘made do’ and lived with the least bad compromise.

I love that statement. I do not mean to disparage.. .. .. but as is usually the case when someone says something like this – watch I, I am just about to. I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all.

Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited

Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.

Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR.

Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.

It is not hard to see that this seems rather irrational if you live anywhere else in the world since no other country has seen a requirement for an IMC like rating.

Canada was just about the only country that saw the need for adequate liquidity control of their banking sector – what a fatuitous statement to make, in a world in which the largest population of GA pilots has solved the problem in a different and very effective way as has the third largest continental GA population and the majority of the rest of the world hardly has any GA or any GA that needs to fly in IMC.


It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents.

Extraordinary. I can find no data, but rather than concluding I can find nothing to support the safety case one way or another, I will conclude the rating is unsafe.

On the basis of the only two surveys of IMC holders of which I am aware

Which two, conducted by who and when?

It is true that training and testing standards are far more variable in the US than the UK and while I have come across no evidence of outright corruption, it is almost certainly possible to get an ‘easy’ IR.

Why would you pass this observation? As “easy” as an IR in Poland?

It is greatly to EASA’s credit that in spite of their enormous workload they accommodated UK minority concerns even though they were often expressed in unhelpful ways. In a public meeting I attended, a well known GA figure suggested that we needed an IMC because England stood alone against the Nazi hordes in the Second World War

Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.

I could go on, but frankly I am bored.

It is just complete dribble.

[FREDAcheck]

Quite right Utfart, it doesn't say (in the FCL.008 ToR) that it will save the UK IMCR. Nor does it say it will do anything else, except "review" and "consider".

It says "...consider whether there is a need for a European rating to fly in IMC... [with sub-IR training and privileges]" and it says "...evaluate the possiblity of reducing the requirements [for IR training]".

Your reading of the ToR is correct only if they recommend a separate rating which meets the needs of a sub-IR. Those of us in the UK that use the IMCR are strongly of the opinion that the talked-of EIR rating is pointless and nowhere nearly meets the need for a sub-IR. The reason for the vitriol aimed at Jim Thorpe is that the EIR looks like an excuse to say "we've considered a sub-IR rating" without actually doing anything useful. I'm more charitable towards Jim's motives, but I consider his judgement rather flawed in this respect.

[IO540]

Nor does it say it will do anything else, except "review" and "consider".

That is all that an EASA committee can do.

[Utfart]

It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents.

Please go ahead and post the next sentence in the letter and explain to us why you chose to exclude it. The fact is he has allowed that the opposite point of view could be true and there there is a lack of data to support either case!

Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.

In fact, the largest population of IR holders have to pass a biennial flight review (that's every 24 months), but you have conveniently missed the currency requirements that must be met to legally fly in IMC as pilot in command. They are; 6 approaches to landing within the last 6 months, as well as intercepting and tracking a course through the use of navigation systems, and holding. Are there currency requirements for the IMCR?

Your logic and arguments remind me of my opposition in the old union busting days in Canada. Reliance on half truths and ignorance. THAT is boring.

FREDAcheck. I'm afraid your reasoning doesn't explain all the vitriol aimed at Jim Thorpe. We must look elsewhere for that and find it in ignorance, misunderstanding, and perhaps guilt. Yes, guilt by those who have been caught unaware by their lack of attention and diligence. I'm not in the aviation business and pretty busy with my work and family, and yet have not been surprised by much of what I read the last few weeks at all. How can that be? Glad I'm not in the AOPA UK. I respect what you have said, and maybe Mr. Thorpes' judgement can be debated. I am very grateful for his decision to share insight and comments on the process he took part in though, else we would have no news whatsoever.

[421C]

Utfart,
Thank you for bringing some objectivity and a fresh pair of eyes to this discussion.

I didn't have time to dissect Fuji's post, but now you have started, I'll continue

Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited

Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.

You can't deconstruct an uncertainty into a certainty by saying it was "hidden", or suggest something untoward by the use of possibly. Possibly alien life forms have visited Earth. Is that "a statement hiding behind a possibly"? No. It is what it says.

More importantly, there is the factual point that an IMCr may be taught by an instructor who does not have an IR. Personally, I have no problem with that - I think flight instruction is more about motivation and teaching skills and currency in teaching than it is about other experience. Also, I think the IF course is the same as the IRI and a very good course. Nevertheless, the point is factually true an IMCr holder may flying IFR departures, enroute, arrivals and approaches having had their entire instruction conducted by someone who wasn't an ICAO IR holder themselves. I am not making a judgement either way. I am stating a fact. That fact may not concern you or me, but there are stakeholders in the UK and Europe, I suspect, who don't think it's acceptable.

Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.He is making a point that balance and maturity are not exactly hallmarks of some of the IMCr campaigning and that this, at times, may be counter-productive. I imagine the irony is lost on you.

I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all
You don't get it, do you. The European system has evolved 2 features
- standardisation through the JAA and, now, EASA
- a "standards paradigm" (I hate the word but can't think of a better one) which is distinct and very firm in the European regulatory mindset.

In respect of training, that standards paradigm involves
- long, structured courses of Theory and Flight training
- written exams conducted by NAAs
- flight courses conducted by FTOs with all the approvals paraphenalia

From the EASA point of view, it doesn't matter that the IMCr has "stood the test of time". EASA's goal is about raising safety standards to a common level in Europe, as defined in the thousands of pages of JAA and, now, EASA documentation. Your inability to grasp this point is why you will be typing the same stuff post after post after post. It doesn't matter. Whatever the strenght of your claims about the record for the IMCr (most of which I agree with), it doesn't fit the "standards" of EASA.

I can't think of a single new European/JAA regulation or restriction that didn't replace something that previously had "stood the test of time" equally well. What happened to the old self-improver route to the IR? What happened with smaller schools teaching commercial stuff? What happened to independent engineers? What happened to engines running more than 12 years? The list is endless.

You have got the entire debate the wrong way around. You think EASA or someone is killing the IMCr because they have a case that it is unsafe. You write thousands of words opposing that. Most of them I agree with. You've used a legal analogy before and one is useful now. You are in an empty courtroom defending the IMCr against charges no-one has brought.

EASA are in a different courtroom. The EU has legally empowered and directed them (it's the EU Basic Regulation laws, not EASA's discretion) to
1. develop a set of high common standards for aviation regulation in Europe
2. standardise those across the region without national exceptions

It doesn't matter that the IMCr is safe and has met the test of time. A million non-EASA or non-JAA practices and methods meet the same criteria (eg. the entire FAA system). Europe has chosen a different model. You can either choose to do your best within the model we are in, or you can write endless posts which are irrelevant. Good luck in overturning the entire European regulatory paradigm in your "campaign". I think this is an ambitous goal. Achieving it may need a brief respite from your main activity of slagging off Jim Thorpe.

I absolutely understand the apparent contradiction between the proven IMCr and the unproven EIR.

At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".

The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.

Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.

Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of all these "restrictions"?
- err, nothing

The reason FCL008's output is the best achievable for GA is that EASA's current "baseline", the IR, is simply not up for debate. Jim's success on behalf of GA has been to
- push for a more flexible, competency based training method towards the IR
- push for the IR TK to be more relevant to the privileges granted.
The EIR is perhaps achievable for the very reason its privileges are meaningfully limited. Approaches and departures are the hardest part of IFR training and flight. If a safe model for the EIR and its privileges can be defined (and I agree it's a new concept, so far from certain), then it is probably the best "sub IR" that can be achieved at a standardised, EASA level. The problem with all the "sub IR lite" proposals is that they openly tweak the privileges and then implicitly flip the training paradigm from the "EASA high standards" one to a more informal IMCR/PPL/FAA traning model. EASA won't accept that. You can tweak privileges and training in a consistent manner within the EASA training model (as the EIR tries to do), but something outside that model (as the IMCr is) will not be accepted in Europe.


brgds
421C


As a final thought, if his article was so weak and dribbly, why not try writing an article or paper of your own? Let us hold your writing and analysis to the same scrutiny you apply. It would be illuminating.

[FREDAcheck]

FREDAcheck. I'm afraid your reasoning doesn't explain all the vitriol aimed at Jim Thorpe. We must look elsewhere for that and find it in ignorance, misunderstanding, and perhaps guilt. Yes, guilt by those who have been caught unaware by their lack of attention and diligence. I'm not in the aviation business and pretty busy with my work and family, and yet have not been surprised by much of what I read the last few weeks at all. How can that be? Glad I'm not in the AOPA UK. I respect what you have said, and maybe Mr. Thorpes' judgement can be debated. I am very grateful for his decision to share insight and comments on the process he took part in though, else we would have no news whatsoever.
Utfart, please don't assume false and insulting motives by others. I'm not doing that about you, even if I think your comments wrong.

This has been a constant theme: those opposing IMCR use terms like ignorance, guilt, lack of diligence... and on other threads: "die-hards", "stubbornly defending", or referring them as too lazy or too stupid to get a "proper" IR.

Why are people so threatened by the IMCR? You may not think it has any chance of being agreed by EASA, in which case, just smile quietly and ignore people pressing for it. I don't think anyone is trying to impose IMCR on other countries (though I think it might be a good idea). No one is trying to make anyone else do anything they don't want to. We're just trying to persuade people to let the UK continue with a rating that is wanted and serves a useful purpose. I think there's evidence that it improves safety, but there's certainly no evidence that it causes harm.

So what's the problem?

[Captain Stable]

I don't know about other schools, but the one where I have been known to cause studes a load of misery has four people qualified to instruct the IMCr.

All of us hold IR's.

[Fuji Abound]

It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents. One might argue polar opposites.

Here is the "missing" line. Note that Mr Thorpe says I can find no credible evidence to support this. A statement of apparent fact. He doesnt go on to say "I could equally argue the polar opposite" but vaguely acknowledges there might be other arguments, by the use of "one might". I dont see on any basis that is a reasonable and unbiased account of the position, it is a clear statement by Mr Thorpe that he has considered all the evidence and he cant find anything to support the IMCr as having any credible safety benefit based on what he then acknolwedges as inadequate data. I would love him to be in Court as an alledged export witness being cross examined on the position he has adopted.

So Mr Thorpe you have considered the data, which you acknowledge is inadequate and you have concluded based on this inadequate data that there is no credible evidence to support the IMCr, rather than concluding there is no adequate data to deteremine whether the IMCr is of benefit to safety or not.

This is what I would have said.

I have considered the studies that have been conducted into whether or not the IMC rating enhances pilot safety and I have reviewed the data on the number of hours flown and the ratings held by pilots involved in accidents. In my opinion the studies and data are inadequate to reach a safe conclusion as to whether or not the rating enhances pilot safety.

I would add that I dont subscribe to that view point based on the data and evidence, but that is another matter, at least that would be a reasonable opinion to express by our self proclaimed expert.

On which point given that Mr Thorpe is just such an expert it would be interesting to know what research and studies he has personally been involved with?

On the stand I can hear the barrister asking Mr Thorpe to set out his creditials. He owuld of ocurse real off that he holds an IR, CPL and doubtless a few other qualifications. So Mr Thorpe to set yourself apart from your everyday peers doubtless you will tell the court your special areas of expertise, the studies you have conducted, the papers you have written, by who they have been peer reviewed etc. I wonder what his answer would be.

Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR.

What do you not understand about renewal checks?

I didnt use that term Mr Thorpe did! He could have said that IMCr pilots are not subject to the same renewal checks AND currency requirements of other IRated pilots BUT he didnt.

You might think I am being picky. You would be wrong. This should be a carefully crafted "write up" by an expert either giving his personal views or representing the views of FCL008. There can be no room for a document as poorly drafted as this with such potential to mislead. If a forumite had posted the same nonesense on here it would have been torn to shreds by people like Bookworm - you know it, and I know it, and he knows it, please dont make excuses.

421C

What I dont get is other people just keep telling you, you are wrong. I could understand if they kept telling me I was wrong - I would have to review my position - but they dont.

You will find if you give it a chance the critique of Mr Thorpe's write up will come thick and fast - so even if you think it is well drafted most people have formed quite the opposite impression. :}

[Saab Dastard]

bose-x, Fuji Abound,

Play the ball, not the man.

SD

[Captain Stable]

bose-x, your post is frankly very insulting.

I have seen no slander of Thorpe on here. Any and all allegations that I have seen are borne out by the man's own words.

It is clear that the majority here do not support Thorpe's proposal or position. Fuji, BEagle and others have put a very good case for retaining the IMCr. It is a case with which I agree.

Are you going to call me stupid as well?

[Fuji Abound]

Saab / Bose

Sorry if I got drawn into making anything personal, that was not my intention. You are quite correct that should have nothing to do wth the debate.

It is clear that I fundamentally disagree with Mr Thorpe's views and the way he has "professionally" conducted himself. I dont know Mr Thorpe from Adam; I am sure he is a perfect gentleman. However anyone who sets themselves up in the role he has must be subject to scrutiny - that is part of our democratic process, of which I would expect no more and no less. However I have had the courtesy to set out exactly why I disagree with his statements and views - it would be unforgiveable if I attacked Bose or Jim without explainng why which I have always sort to do.

[Fuji Abound]

Nevertheless, the point is factually true an IMCr holder may flying IFR departures, enroute, arrivals and approaches having had their entire instruction conducted by someone who wasn't an ICAO IR holder themselves.

I agree, but it is again not what Jim said. He could have said exactly that, but he preferred to say "whose own experience is quite limited". What does that mean and who has assessed whether their expereince is limited. My IMCr instructor all those years ago I can guarantee you had more experience of IF than Mr Thorpe and most pilots with an IR even though he did not hold an IR.

I imagine the irony is lost on you.

The irony of mentioning in a "technical write up" that some nuter made such insulting remarks that were totally irrelevant to the matter in hand. Sadly I dont think the intention was irony but a feeble attempt to tarnishing the protagonists with the same brush. However, which ever way you read it, it would as ridiculous as Mr Brown talking about climate changing and bereating the nuter that poored custard over Madelson.

From the EASA point of view, it doesn't matter that the IMCr has "stood the test of time". EASA's goal is about raising safety standards to a common level in Europe, as defined in the thousands of pages of JAA and, now, EASA documentation. Your inability to grasp this point is why you will be typing the same stuff post after post after post. It doesn't matter. Whatever the strenght of your claims about the record for the IMCr (most of which I agree with), it doesn't fit the "standards" of EASA.

I find that a sad inditement of the whole process. You seem to be saying it doesnt matter to EASA whether or not there is a proven safety case, we are far more concerned with a common standard. EASA is mandated to safety by way of common standard.

[BillieBob]

I have stayed out of this little spat until now as I have no interest in the IMC Rating but there is one statement that I cannot let pass without comment.
EASA's goal is about raising safety standards to a common level in EuropeThis is simply not true. The fact is that EASA's goal is about achieving a common level of safety standards in Europe that will involve some countries (mainly in the south) raising their standards and others (mainly in the north) lowering them. As with everything EU, it's all about 'one size fits all' which, of course, it never does.

[IO540]

I think it is far from certain that the IMCR is going to get killed off.

When the EU started going on about animal rights, they got the chief on TV and asked him about bullfighting in Spain... his reply, with a smile, was along the lines of: politics is the art of the possible :)

What I think people are most worried about is that the IMCR will get negotiated away, while the promised replacement will never come. The "more accessible IR" has a history longer than the 10 years I have been flying, with loads of failed promises, with proposals frustrated at each stage by very well practiced commercial / job protection / elitist interests, and plain inertia.

Maybe EASA has a better chance of doing something on this front but to date there is no evidence to support that belief - unless one assumes that since EASA is a bigger fatter kid than any previous ones, it has a better chance.

I also think that their aggressive stance to do with banning foreign licensed pilots flying in Europe if they are EU residents is going to hit the buffers; obviously I hope it does. This proposal was IMHO a piece of stupidity because there is no realistic fallback / face-saving climbdown position. They bet the whole shop on the USA climbing down and signing a reciprocal treaty with that pompous little hole called Europe. But because this is lumped in with all the other year-2012 stuff, the whole lot might get sunk together. And then if the IMCR is lost as well............. ?? The only accessible IFR option will be the FAA IR, which nowadays means a significant residence at an American motel :)

[robin]

EASA's goal is about raising safety standards to a common level in Europe
This is simply not true. The fact is that EASA's goal is about achieving a common level of safety standards in Europe that will involve some countries (mainly in the south) raising their standards and others (mainly in the north) lowering them. As with everything EU, it's all about 'one size fits all' which, of course, it never does.

Not quite true

I was at a meeting where it was made abundantly clear that

1) Despite its name, there is actually no part of EASA concerned with Safety.

2) EASA is a political organisation where most of the rules are constructed by lawyers working to a brief to bring standardisation (and nothing else) to the EU members.

These are the lawyers who insisted that for 'neatness' balloons would need to carry serviceable ASIs!

The default position is that when constructing rules, national exceptions are anathema, but they start from the premise that what the French do is the baseline. Only in exceptional circumstances will there be opt-outs.

The French get their Brevet de Base and Mountain Rating because they play it cleverly.

We don't get involved in the game and can't get even the simplest opt-out.

Once our leaders (whoever they may be) start to understand this and work with each other, we might start to get somewhere.

The way to guarantee failure is to sound off about how the UK does it better and safer than everyone else in Europe. Oh, and to send out our reps with no defined position helps to really screw things up.

[BillieBob]

Not quite true....Despite its name, there is actually no part of EASA concerned with Safety.Whilst it is true that there is no one department within EASA whose function directly and specifically includes 'safety', one of the first statements one comes across on the EASA website is
Our mission is to promote the highest common standards of safety and environmental protection in civil aviation.Therefore, it is a little disingenuous to imply that EASA is concerned only with standardisation and not specifically safety standards.

The important point is that, having made such a mission statement, to accept anything less than the very highest safety standards is to immediately fail in that mission. It is thus clear that, by its very nature and composition, EASA is bound to fail - some (many) would say that it already has.

[Pace]

The way to guarantee failure is to sound off about how the UK does it better and safer than everyone else in Europe. Oh, and to send out our reps with no defined position helps to really screw things up.

Robin

There is a huge arguement made about the IMCR and safety benefits!
That implies as a IMC flying rating it has safety benefits which it does not,
To do that you would need to compare the IMCR to other IMC flying ratings ie the full IR.

THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,

The easy answer to that is to have the enroute privalages suggested with approach privalages only in an emergency and with a special call.
This would mean you were treated as an emergency and vectored onto an ILS by ATC: Argue the safety angle and thats all you may get on safety grounds with no furher safety arguement.

Hence why I plead to put all efforts towards an easier not less quality IR.
I know the above is not what IMCR holders want. They want the IMCR to be a mini IR in the UK and Europe.

But plead the safety angle and thats all you will or should get on that arguement.

Pace

[flybymike]

The easy answer to that is to have the enroute privalages suggested with approach privalages only in an emergency and with a special call.
This would mean you were treated as an emergency and vectored onto an ILS by ATC:

Without automatic IAP privileges attached to an EIR the pilot is not going to be in current practice or carrying, or familiar with, any particular ILS plate/procedure. In a true emergency any pilot is going to opt for the lowest work load option, ie a vectored SRA approach.

When I did my PPL 27 years ago, this scenario was precisely what the instrument training and SRA part of the syllabus (applicable in those days )was intended to address.

[FREDAcheck]

THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,
Pace, not only do I think that incorrect, but the CAA would appear to as well. Your statement is not consistent with the privileges of the IMCR.

[robin]

Pace

My point was not that making a safety case was invalid, it is that the EU generally get upset by arguing on a national basis.

The IMCr is being seen as the UK solving a problem that does not exist elsewhere in Europe (whether that is true or not, that is how it is seen) and the other members don't take kindly to the UK trying to railroad them into taking a different line, based on national interests.

All other countries engage in a lot of behind the scenes negotiations and horse-trading. I don't think the UK reps at political level, where it counts, do that well enough.

[Pace]

Freda

THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,

Please explain which part of my statement above is incorrect? I know what it is used for but that is not the safety benefits of the rating,

I hope you are not trying to say that the IMCR has safety benefits above other IMC flying ratings if so which? I repeat the safety benefits are to VFR pilots who get into non VFR conditions.

To the other poster how many PPLs with IMCR could be classified as current on instrument approaches? very few have the money or regular IFR flights and approaches to be so.

Pace

[FREDAcheck]

Pace,

Perhaps I did not understand the intention of your post?

I inferred from your remarks that you consider the IMCR rating is intended for VFR pilots who plan only VFR flights, to help them if they accidently encounter IMC. I disagree with that. The rating also allows for planned IFR flights into IMC, including planned, intentional instrument approaches.

However, if you are saying the safety benefits accrue only to VFR pilots who fly in IMC – well, that’s sort of self evident, and non-VFR pilots already have a rating to fly IMC, that is IR.

But your wording ("THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land") suggests the former, with which I do not agree. The IMCR is also for intentional IFR flights.

I think I must have missed your point.

[IO540]

Pace

how many PPLs with IMCR could be classified as current on instrument approaches? very few have the money or regular IFR flights and approaches to be so.What would you say is preferred :

1) An IMCR holder who is less than current but who is legal to land on an ILS

2) An IR holder whose IR lapsed a long time ago (because he can't afford his own plane) who dabbles in IFR here and there (because he can't do it overtly) and whose ability to fly the ILS is probably the same as the above IMCR holder

??

I got the IMCR in 2002 and got the IR in 2006, having been flying airways in Europe since 2005 with an instructor.

I don't see the difference in the end product - once the memory of the checkride (my FAA IR one was incredibly hard) fades away.

Basically, a pilot will be only as good as his currency, which in turn depends on

- funding
- a keen interest in aviation and going places
- funding
- spare time to fly
- funding
- spare time to fly (most people with the funding don't have a lot of spare time)
- a keen interest in aviation and going places
- aircraft ownership (more or less mandatory for going places)
- aircraft equipment and his comprehension of it
- his ability to make optimal use of cockpit automation (i.e. none of this "I have an autopilot but don't need it so I fly by hand" crap)

I have a CPL/IR but apart from chandelles and lazy eights (which were great fun), the IFR lost comms procedure, and one or two other snippets, I learnt nothing in the CPL or the IR that is relevant to real flying - over and above what I knew before doing them. Nearly all of the knowledge I use on real flights was learnt elsewhere - probably from other pilots, probably via the internet. I knew more about IFR, high altitude flight, oxygen, airways route planning, etc in 2005 than my IR instructor, and this was fairly evident...

I think that IFR is actually really easy. You have to know about strategy relative to aircraft mission capability and weather / icing etc. Somebody really dumb can learn to fly but they will fail in these more advanced areas. But IFR was hard, the whole earth would be covered in wreckage, which it isn't.

What you have to do is read the plates and fly them. If you fly them wrong, you will probably die. Nothing new there. If you drive on the wrong side of the road the same will probably happen.

I think the emotion about the IR being something "special" is the result of a deep realisation that IFR is really easy and almost anybody with a half decent brain and the ability to read a plate, who can fly headings and levels, and who can operate the aircraft technically, can do it and provided they don't make a c0ckup, they will be safe and correct. But if this knowledge was to get out of the IFR pilots' Masonic lodge, their professional status would collapse.

A lot of IMCR training is crap, but a great deal of PPL training is also crap. And don't I know it - I could tell a few stories myself about mad instructors. The initial IR test in the UK is done by CAA employees, but that isn't the case in the rest of the known universe so there is no evidence that this consistency in the very early stage has any long term safety benefit. The UK IR test is a very narrow airways flight exercise which AIUI any monkey who trained on those routes (which they all do of course) can fly. After a while, none of this means very much.

I have met crazy lapsed IR holders and crazy IMCR holders, and crazy PPLs. Some crazy CPLs too. After some passage of time, all these bits of paper mean sod-all. If I could pick up a JAA ATPL by finding that Mongolia will convert my FAA CPL/IR into a Mongolian ATPL and then Mongolia joins the EU and becomes JAR-FCL compliant, and it charged me Euro 3000 for it, I would do it right away. In the longer term, the pilot is only as good as his attitude, intelligence, and funding. The bit of paper just sets the privileges.

What I do think is a shame is the lack of operational detail training. The PPL is claimed to be a preparation for all kinds of flying but actually it leaves the graduate unable to really go anywhere. The IR is similar - it doesn't teach the operational details of flying especially in the European IFR system. But no training syllabus is going to ever address these things. After all, over here, they are only just getting their hands around GPS - 10+ years after it became the de facto sole nav method for IFR.

[Utfart]

Utfart, please don't assume false and insulting motives by others. I'm not doing that about you, even if I think your comments wrong.

This has been a constant theme: those opposing IMCR use terms like ignorance, guilt, lack of diligence... and on other threads: "die-hards", "stubbornly defending", or referring them as too lazy or too stupid to get a "proper" IR.

Why are people so threatened by the IMCR? You may not think it has any chance of being agreed by EASA, in which case, just smile quietly and ignore people pressing for it. I don't think anyone is trying to impose IMCR on other countries (though I think it might be a good idea). No one is trying to make anyone else do anything they don't want to. We're just trying to persuade people to let the UK continue with a rating that is wanted and serves a useful purpose. I think there's evidence that it improves safety, but there's certainly no evidence that it causes harm.

So what's the problem? I don't feel I've made any wrong assumptions about people's motives, there are clearly two camps in the argument. Maybe I've been misunderstood by my lack of position on the issue. Allow me to clarify, I don't care about the IMCR as I don't fly in the U.K., if it remains in place 10 years from now, or even becomes available in Europe, it won't have any impact on my life whatsoever.

I have not meant to use the terms ignorance, and lack of diligence, to a attack defenders of the IMCR. It was intended to point out that those whom many have trusted (and paid) to represent their interest, seem to have done an extremely poor job. Regardless of our opinions on the work of Jim Thorpe within the FCL.008 committe, he was the EAS delegate. Why no attack on the AOPA rep on the commitee? Why no attack on the organizers of AOPA UK who didn't manage to get a rep on the commitee? Mr. Thorpe has chosen to publish some information and I'm sure he knew there would be dialogue. I don't feel sorry for him and I'm grateful for the information, but the news he told us wasn't really a surprise, and nothing different than one with knowledge of the mandate should have expected.

I'm in favour of any additional training undertaken by pilots, it can only be a good thing. I was motivated to comment by my perception of a lack of focus in the debate. No personal insult was intended.

[FREDAcheck]

Utfart, thanks for the clarification. I certainly mean no insult to you either.

[Sir George Cayley]

If EASA doesn't encompass safety, what's the S for? Also, have a look at this link ECAST (http://www.easa.europa.eu/essi/ecastEN.html)

I think the level playing field objective comes from the old EEC where the removal of barriers to free trade within Europe was a main column in the the Treaty of Rome.

For the regulation of aviation EASA have already signaled that rules should be proportionate to the operation being regulated. They also have adopted AMC's to permit states to come up with ways of meeting Implementing Rules.

Lowest Common Denominator (LCD) will be the eventual result.

But wait, the IMCR is a national scheme just like the NPPL, the CAA will continue as an NAA doing EASA's work in the UK. Some aspects of UK aviation will fall outside the scope of EASA rulemaking and hence the CAA will have to devise ways regulating these 'left overs'.

Why not propose to the Captain of the Belgrano that we do things the French way? Sign up to the EASA IR but carry on as before with our UK IMCR. It could just work - couldn't it?

Sir George Cayley

[Pace]

Freda Check

Firstly let me make it clear I am not anti the IMCR or its benefits. The only point in its defence Europe wise is that it does add to the safety of VFR pilots.

I do not see any danger that UK pilots with IMCR will suddenly find they can no longer fly in cloud. Equally I do not see any chance of the IMCR being accepted in Europe.

There is a small chance that there is a window of opportunity to get a more attainable IR but on focusing on saving the IMCR (which wont be lost anyway!) we will loose the real prize of a more achievable IR.

So lets all shoot ourselves in the foot by chasing a Red Herring and not being able to see the wood for the trees

Pace

[Fuji Abound]

see the wood for the trees


Clearly a man who has spent the day watching the golf news.

[Pace]

Fuji

No sitting in a hotel in Berlin just about to go out for some food with my co pilot. Back to the UK tomorrow in a Citation :) So IFR filed FL360 on an FAA ATP. Strange how we use the same airspace but dont accept each others licences :ugh:

Pace

[Fuji Abound]

Pace

Have a good one, your co-pilot clearly cant be very attractive as you have been looking at the screen a fair bit. :)

Here is a thought that might keep you happy.

Leaving aside what may or may not happen in the UK, I think we all understand that the IMC rating sits uncomfortably in a system where there is no IFR in open FIR.

Where ever you place the IR pole, the IMC rating sits below the IR pole and yet if the IMC rating entitled the holder to operate in airways there is little to distinguish an IMC rating from an IR. If there is so little distinction between the two ratings then once must fail. Clearly it cannot be the IR because of the two that is the only rating that achieves ICAO status. The UK of course found a peculiarity of its airspace structure which enabled the IMC rating holder to be prohibited from flight in class A. Thus, there was a clear distinction between the privileges of CAA IR and CAA IMC rating holders in UK airspace.

The EIR attempts the same trick in a way compatible with European airspace (including the UK for those who think we shouldn’t be part of Europe) by distinguishing between IR holders with approach privileges and EIR holders without approach privileges (if the rumours are creditable). Unfortunately this is a very poorly executed trick because there is nothing more ridiculous than allowing a pilot to climb through cloud and then ask him to write his own ending.

So if there is to be a pan European sub ICAO IR a solution must be found which is based on exactly the same slight of hand that the UK found worked so well.

Mr Thorpe was right; you must permit the holder access to class A airspace or at least the lower airways whatever letter of the alphabet you assign to that airspace. However, we pilots are not good story writers, so rather than write his own end every time a way must be found of allowing the pilot to follow the script. In our hearts we all know that is the safer option which is why we all get so excited about made up cloud breaks on a hope and see basis. Moreover, the system is not constructed for us to do so – for that reason the EIR would make mavericks of pilots using the EIR in any meaningful way.

Aside form there being a philosophical need to distinguish between the privileges of an IR holder and an EIR holder there is I believe a safety case. In reality so far as instrument flying is concerned more accidents occur on the approach than during any other phase of instrument flight. It is of course the one and only time we are intentionally closing with matter not compatible with flight or our health. Moreover the closer we get, the smaller the margin for error. As some narrators have pointed out the UK also sits peculiarly in terrain in which we haven’t built airports in mountainous areas. That enables the draftsmen to write approaches which have much more margin for lateral separation than some approaches in Europe.

There has been much debate over whether the recommended minima for IMC rating holders are more than recommendations; whatever the original intent the draftsmen was either having a bad day or had his mind on something else. When I passed my IMC rating a long time ago I thought the higher minima were mandatory and operated to those minima. The higher minima suited me; it took me a long time to feel completely comfortable with popping out at even 400 feet, never mind lower.

I fly for business and pleasure. There are days I really need to fly, but never days I have to fly. In fact since most of my business is in the UK although I kid myself it is faster by aircraft than car when I add up the whole journey there is rarely much in it unless I am going to the I of W (or the CIs) but in the case of the former I don’t have the luxury of an instrument approach in any event. I guess there are a few GA pilots who have to fly, but I would equally bet there aren’t many. Moreover even with an IR and an aircraft that is de-iced there are still 10 days out of every 100 I wouldn’t choose to fly.

For me this means that I rarely see minima’s; and when I do they are not by choice unless I feel a desperate need to fly one, and often it will be with a mate of mine who is a training captain with BA. Checking my log book I have flown to minima’s three times in the last year of which one required a diversion. Am I unusual – I don’t think so?

Where is this going?

Well, we need to find a distinction between the privileges of an EIR holder and an IR holder. We have talked our selves into believing an EIR holder needs more protection than an IR holder and we have acknowledged that the most dangerous part of an IF is the approach. I think we might also all agree the danger increases the lower we get OR in circumstances where the approach is less protected from surrounding terrain. I don’t suppose any of us would argue that vectors to a cloud break on the localiser at minima plus 500 feet should unduly tax an instrument trained pilot. I know, what about the approach in Geneva – and I have flown it! We all check the plates before we launch don’t we? After all it is a legal requirement. The airport authority in conjunction with the national regulatory authority (will that become EASA?) writes the AP for every airport. Perhaps where the IAP falls within certain parameters there might be a caveat under the minima box – NAEIR – not available for EIR holders.

I wonder.

And perhaps the UK would nearly keep its IMC rating privileges at most of its airports by one means or another.

Wouldn’t that be a clever trick?

[Sick Squid]

I don't think classifying instrument flying as easy is either relevant, valid or realistic. In my experience, some of the hardest challenges I have faced have been fully on instruments. Then again, a night visual into some black-hole Island is also challenging.

Perhaps the reason someone would think it was easy is because they have never been loaded up under those conditions? Throw in a couple of failures and a requirement to nail your minima, and the "ease" of flying on instruments might not appear quite so apparent, even without the "masonic"handshakes. After all, if it was that easy, why do professional pilots require a retest every six months, and a revalidation every year? Put someone behind you marking you on that particular venture, and suddenly the ease seems to disappear, does it not? Particularly when your licence is on the line.

Instrument flying is a skill, but it is not like riding a bicycle. If you do not practice it regularly and honestly it will fade. No amount of secret "IR handshakes" will save you then. You might gather I feel that part of the post above was rather frivolous and mistaken.... no-one ever gave me a handshake, and at least once a week I take everything out and practice instrument flying, because I have to. To keep safe, current and relevant. And yes, if I don't do it, I do notice a difference.

So no, IO540. Instrument flying is not easy. It is a skill that has to be practiced. If you find it easy, then bully for you; I don't, never will, and should the day arise I do then perhaps that is the day I will should flying.

{edit} On Reflection, that comment seems to me even more wrong. I'm thinking about flying ATP into the Scottish Islands, at night, in turbulence with no autopilot available, and having to absolutely nail it. I'm also thinking about an approach I did into an African destination with the ITCZ right over the top having to gash a localizer-only approach from 15 miles out as the glideslope had just become u/s and the marker crossing height was 1200" above the field, and that was where the approach started from, and we were coming in at 3000". Where to descend? When to descend? How to calculate that point of descent bearing in mind you can't dive-and-drive an airliner? And what to then do when the right-seat pilot (training Captain) is telling you you are 500" too high.... a quick glance right showed his clock was out from mine as it was all timing based and I'd checked mine on the overhead. But easy? Some secret handshake? No, I think not.

Or the VOR I screwed up into the Bahamas a few months back, not flying it accurately enough so we had to go-around and only got in on a "Highlands Visual" ie "I can see the coast, I know how to get to final from there, you happy? If you are tell them visual and we'll go for it."

So no. Not easy. Never has been, never will be and can bite you in a moment. I would not be happy flying behind anyone who feels IFR flying is easy, and part of some "Masonic" conspiracy. Sorry.

Squid

[IO540]

SS - you are taking my comment out of context. Yes, airline pilots have a line check every so often but they do it on a representative cockpit, not in some GA spamcan in which few people would fly IFR for real, partial panel and with the moving map GPS switched off for the very bits where you want the best situational awareness... Airline pilots also have to fly (subj. to wx above company minima) else they get the sack; a private pilot will generally pick another day. I take my flying pretty seriously but cannot help reflecting on how irrelevant the training practices are to reality.

in turbulence with no autopilot available,

A private pilot would not depart IFR with no AP. One can do the flight but the cockpit workload is high, so why go? I've flown to Greece and back manually (due to AP failure on the way) but would not depart with a duff AP. I know the Trislander crews were/are flying manually - hard work.

[Sick Squid]

I don't agree with you that it's out of context. It actually strikes right to the heart of the argument I would espouse that there should be two completely separate disciplines in flying, vis. instrument and visual with no middle area in between where only certain instrument skills are taught and allowed to apply to lowered minima. It is that lowering of minima for planning purposes, and perhaps also the relevant increase in "perception" of skill that I feel should not be part of regulation. The fact that it was in the UK is, again in my opinion, unfortunate.

Practice is the relevant verb here, and yes, from your post above I see you agree on that. What I would argue is that is practice and checking of skills is perhaps more relevant than most people realise. In an ideal World I'd see an increase in basic IF flying taught in training, and checked every year as part of licence revalidation as a "get my ass out of the ****" skill. As for full IFR flying, then that again should be checked separately, and with failures thrown in. All just my opinion, and I do realise there would be a financial cost with that, but so be it, I feel it is that significant an issue.

The ATP reference to no autopilot was simply that it was not available in turbulence. We could, and did often depart with the whole thing u/s, but again we were a multi-crew environment. IFR single-pilot is a call that would always require a second thought, and respect to those that choose to do such.

Regards,

Squid

[englishal]

Flying IFR is easy under normal circumstances IMHO. It is even easier for airline pilots - for example I flew from London to LA on a B747 recently and the amount of time spent in IMC was oooohhh....Nil. I've flown my fair share of light singles and multis without AP and basic instrumentation and enjoy it. I wouldn't do it for 600 miles though, but a hop from Jersey to Bournemouth---no problem.

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too.

Requirements for the "commercial" IR should be a formal course and exams OR a Private IR already held and some other stuff.

It really is so easy so I just don't know why this won't happen. I suppose it is a function of being in europe , with too many people who will never agree.

[mm_flynn]

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too.To a very real extent that is true in FAA land and if the FCL.008 proposals on the more sensible IR come to pass it will be true here as well. (In the sense that the commercial stuff is included in the commercial licences and in the US the ATPL ride and type ratings have significantly tighter IMC tolerances than the IR).

I have disagreed with a lot of what Fuji has said, but his most recent post seems like a very sensible strategy to go forward with.

[Fuji Abound]

I have disagreed with a lot of what Fuji has said, but his most recent post seems like a very sensible strategy to go forward with.


Thank you.

[IO540]

SS

Perhaps my choice of the word "easy" was irreverent but that is just my writing style :)

IFR is a highly structured discipline which has enabled tens of thousands or more pilots from all over the world, with all kinds of education backgrounds, to fly worldwide. And lots of them are landing at LHR as I write this :) Sitting there, twiddling the heading bug according to ATC directions, until getting LOC intercept...

IFR facilitates very easy flight across Europe and its diverse airspaces and its sometimes "diverse-attitude" ATC.

If IFR was hard, few private pilots would aspire to it. Most I know agree with me that the greatest secret of IFR is that once you have passed the checkrides and collected the papers, the actual flying is nothing like as hard.

There are other major differences between commercial IFR and private IFR:

- few private IR pilots would choose to fly the Trilander type ops, occassionally scud running at 400ft above the sea because of hugely limited capability to get above weather

- most private IR pilots have substantially capable planes, in both navigation and altitude

- most private IR pilots don't have to fly; even on a business flight visiting a customer (the hardest kind of "business flying") one can choose alternative transport

- private IFR is done in an empty airspace void; FL100-FL200 in which there is close to zero commercial traffic, and one doesn't get routings through terminal areas where the two might be closer

I can see where you are coming from but I think it illustrates why for years there has been close to zero progress on making the private PPL/IR more meaningful in Europe - while the Americans are laughing all the way to the ILS :) (or I should say the precision GPS approach.........)

For avoidance of doubt: I think an IFR pilot should be trained to fly every type of instrument approach, and holds, and should be examined on these. It is the theory and the mandatory nonsense (industry protectionism like having to do stuff via a professional FTO, and 50/55hrs min dual which is not relevant to demonstrated competence) which needs overhauling.

[421C]

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too


Englishal,

There is today exactly the Private IR you describe. It is the JAA IR. You can't use it for public transport ops unless you have considerable additional training and qualifications
- in a light piston aircraft; CPL writtens, a CPL and all the line/base training and checks required under the operator's approvals
- in a larger aircraft, all the above, plus a Type Rating passed to higher (ATPL) standards and an MCC and the ATPL writtens
and there is nothing in the current flight training and testing which is specific to public transport. The written exams have a few remnants in airlaw which might be considered as such, but let's remember the JAA IR syllabus is already signficantly slimmer than the present one in the UK. It's simply that the UK CAA have not chosen to implement the JAR-FCL amendment and the new question bank that have been available for a year or two.

I wrote a post earlier with a bit about the "privilege limitation fallacy". I don't mean for 'fallacy' to sound derogatory - perhaps 'problem' or 'conundrum' would have been better, but the earlier discussion was a bit more heated...

Let me repost it adding your restriction to the list in underline.


......At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".

The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.

Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.

Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
- can't be used for public transport ops
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of all these "restrictions"?
- err, nothing

What FCL008 is proposing is
- a further reduction in the IR TK syllabus to eliminate items not relevant to the privileges granted. These are not 'commerical' items, they have already been elminated. They are irrelevant depth in the private items.
- a training method more flexible than the current ones, which were primarily designed for the purpose of turning zero-hour cadets into 190hr junior FOs for the RHS of transport jets
But, the irony is that, although the JAA IR training structure was designed to fit the Integrated/Modular routes to a frozen ATPL, the actual content is wholly focused on low-level IFR in small piston aircraft, with no meaningful 'commercial' elements.

EASA has already decided the standards needed to operate a light aircraft under the priviliges of a 'private' IR. They are those of the current JAA IR. All the extra stuff (from Commercial/PT to operating a 3 engine pressurised aircraft with more than 6 seats in RVSM/Oceanic airspace) needs a bunch of extra training in addition to that of the current JAA IR.

No 'privilege limitation trick' is going to change this. If the current JAA IR immediately qualified a PPL to fly commercial or jet stuff, then privilege limitation would work. But it doesn't, because it qualifies you for nothing more, as a PPL holder, than to operate a light aircraft privately under IFR in all phases of flight. Which is exactly what we want in a 'private' IR and exactly what the IMCr does outside Class A. But see above my points on the "Class A limitation".

We may all agree that the FAA methods, lock stock and barrel, are as safe and a lot more flexible and efficient than the European ones. But until someone has a masterplan to overthrow the entire regulatory model in Europe, I think our best bet is to support the FCL008 outcome within the EASA model. Outside of the EASA model, of course, the UK can try and save/exempt/grandfather the IMCr and good luck to those efforts.

[Fuji Abound]

But until someone has a masterplan to overthrow the entire regulatory model in Europe, I think our best bet is to support the FCL008 outcome

That very much depends on which bits you pick:

1. The EIR as rumoured is unsupportable. In fact I think it is dangerous,
2. The lack of grandfather rights (if that is the case) for IMCr holders into the EIR (or at least a realistic conversion) is unsupportable,
3. Since we dont know as usual what the IR concessions will be, there is nothing to support at the moment.

Unfortunately in so far as private pilots are concerned that doesnt leave a lot.

EASA should consider my solution to the EIR problem, but then I would say that. :)

[drambuster]

This has been an interesting thread kicked off by AOPA's article in December's GA magazine which I read with mounting dismay last Sunday.

There have been some convincing posts for the retention of the IMCr by Fuji and others. I am a firm supporter and can attest that at my own flying club the most proficient pilots at combining GA jollys with demanding clag flying (often manually) with IAPs at the conclusion tend to be IMCr holders. Of course they are no different as individuals from the IR lot - but this is all about 'currency' - and the IRs tend to be commercial crew who do it all week (on triple autopilot, auto throttles, full instrument landings etc etc) and by the weekend they are just looking for a different kind of fun - and the prospect of bouncing around in cloud in a spam can doesn't seem to tick their boxes ! (but don't get me wrong - they are top pilots who could do it if they felt the urge)

Sadly I think the current situation was best summed up by mm_flynn:

Blathering on forums, Number 10 petitions, writing to FCL.008, dark threats, etc. are going to wind up with the IMCr holders being left behind. Only realistic lobbying of the key decision makers is going to achieve the objective of retaining all of the current privileges of the IMCr.

PS - no one is 'holding their noses' up at IMCr holders - but the IMCr holders need to fight their battle not hope some Euro committee will save them!!

Until this weekend I thought AOPA UK were leading that battle - based on the magazine article they appear to have been leading from an armchair.

This was reinforced by this morning's review of the latest Loop magazine:

"IMC saved my life" - You respond in droves to campaign to keep UK's IMC rating:
"The campaign to HELP THE MEN FIGHTING TO KEEP THE IMC RATING ALIVE and legal for UK pilots has been overwhelmed by your support . . . etc"

They go on to say:

"Many thanks for all your submissions to AOPA to add your support. Email your testimonials to LOOP . . . . . [and] we will forward them to AOPA's Martin Robinson"

As Cows getting bigger so eloquently put it (post 11):

"at the risk of sounding flippant, WTF is going on ? . . . "

My thoughts exactly :ugh: Who precisely are all these 'MEN FIGHTING' to keep the IMCr? I am an AOPA member and in general I support all that they do . . . . .. but I have to say Martin Robinson now needs to explain exactly what he is up to as the 'campaigning' seems to be getting absolutely nowhere. I have an overwhelming sense that we are losing the battle to keep the IMCr (whether as a UK 'one-off' or some form of PPL-IR) through inept handling of the necessary politics.

How come AOPA UK failed to get a seat at the meeting? How come the IAOPA representative failed to push our case when it must have been obvious to those 'in the know' that Thorpe and his mates would love to see the rating eradicated? Frankly this shows how poor we Brits are at getting our way in Europe - we just don't know how to do it. Very sad as the potential consequences will be absolutely dire . . . .

Mr Robinson would you please post a statement on the AOPA website explaining how you are going to turn this situation around? Can I suggest you urgently engage an aviation lawyer (the Flying Lawyer aka Tudor perhaps?) to advise on how best to improve our lobbying? We only have one chance so please don't blow it.

. . . .. and maybe you should hire a French or German national to front our campaign as at least we won't then miss every trick in the book :}

Finally, under the 'news' section of your website there does not seem to be any reference to the IMC Campaign at all - why not? What happened to the 'urgent meeting' you were having with Mr Eric Sivel? Surely your website news section should be updated every week on matters such as this?

Yours,

(one well and truly dismayed)
Drambuster

cc LOOP and AOPA by email

[bookworm]

Mr Thorpe was right; you must permit the holder access to class A airspace or at least the lower airways whatever letter of the alphabet you assign to that airspace.

Aside form there being a philosophical need to distinguish between the privileges of an IR holder and an EIR holder there is I believe a safety case. In reality so far as instrument flying is concerned more accidents occur on the approach than during any other phase of instrument flight. It is of course the one and only time we are intentionally closing with matter not compatible with flight or our health.

OK. So you seem to agree that we cannot have a meaningful pan-European instrument qualification with privileges restricted by airspace class, and that flying IAPs safely is the most demanding aspect of IF. You want to propose a sub-ICAO pan-European IR based on reducing the amount of training required and applying a restriction to the privileges which is appropriate to that reduction in training. On that basis, I don't think there's any difference between what you, Jim Thorpe, and FCL.008 want to achieve.

Where you differ is on the magnitude/nature of the reduction in requirements and the appropriate restriction of privileges. You want the restriction to be based on higher minima. So the question becomes "what is included in the proposed IR that you not need to know, and that you do not need to be trained to do competently in order to fly approaches to higher minima?" There would seem to be three options for reduction:

1) The theoretical knowledge.
2) The dual training hours required.
3) The total hours of IF required.

FCL.008 came up with the EIR. Same TK. 15 hours of dual instead of 25, reflecting 10 hours less training on IAPs (note, no one has said "no training on IAPs"), and a removal of the 40 hours minimum IF (which is there to comply with ICAO standards). The restriction is yet to be detailed, but I think we can deduce from what has been written that it would involve some measure of avoidance of IAPs in IMC. One could argue that these are increased minima of a particular magnitude.

What's your proposal, and, more importantly, how is it appropriate to the higher minima restriction that you suggest?

[englishal]

and there is nothing in the current flight training and testing which is specific to public transport.
Right - that is the problem.

People like to harp on about the FAA ATP flight test, well the FAA ATP is required to fly certain transport aircraft / ops - namely scheduled airline type stuff as commander.

In JARland we expect our 200 hr C152 and 50 hr SIM pilots to be capable of commanding a 747 as captain under instrument conditions? That is nuts, which is where the FAA 1500 hr ATP minimum and test (and as was the Norwegian system and I believe the UK system too in the old days) makes complete sense. Why not revert the EASA ATP back to that and get rid of this "frozen" ATPL nonsense.

This way we wouldn't have to have a gold plated JAA IR as the only option. Incidentally is it gold plated or not or just anal? On his test / 170A my mate had to "dead reckon" his way to ORTAC on some departure from Gurnsey despite having a fully functional G430 in the aeroplane. That is just plain stupid.

I calculated yesterday that for me to convert to the IR it would cost me £1000 for the ground school, and then abut £500 for the exams, plus the examiners fee of £700 - and that is before one bit of flying. Unless this changes then an IR will be no more accessible than it is now.

I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.

[Captain Stable]

Flying IFR is easy under normal circumstances IMHO. It is even easier for airline pilots - for example I flew from London to LA on a B747 recently and the amount of time spent in IMC was oooohhh....Nil.That the flight might not have been in IMC doesn't mean that it is any easier.

Please do NOT confuse IMC with IFR. We've already had that discussion.

FLying some of the more complicated IFR approaches is pretty damn difficult, in VMC or IMC - it makes no difference. The tolerances remain the same, the possibility of misreading hte plate or the DME is the same, the possibility of busting an intermediate altitude is the same.

If you think being in IMC makes a difference, you know a grand total of ZIP about flying IFR.

Where there is a big difference for a relatively inexperienced private pilot is that, unless practising, he will be flying an approach for real, with few of the toys that Sick Squid has at his disposal, and the pressure will be on. He may be disorientated, worried and distracted by even a small equipment failure. Add in night and poor weather, slight traces of icing... We owe it to him to ensure he is trained to do it. If his training is less than that of an IR, then to higher minima.

Conversely, I accept that a daytime descent through a slight layer of stratus with base at 2000' AGL in +15 degC with a decent 3-axis autopilot switched into the HSI and a serviceable aircraft is not terribly taxing.

But there is little difference in conditions between those two scenarios that is allowable in a rating. One is not nice even for a professional pilot in good practice. The other is a doddle even for an 80-hour PPL.

[FREDAcheck]

I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.
And preferably non-precision, with suitable minima. Why not? Some of the smaller airfields with instrument procedures - the sort that IMCR holders might fly to - don't have ILS. I'd much rather fly an NP procedure to break through a cloudbase of 800-1000 feet than risk it DIY - when the MSA might well be 2000 feet. (We can have a separate debate about what the minima should be - whether the existing recommended 500/600 feet AAL are suitable.)

[bookworm]

FLying some of the more complicated IFR approaches is pretty damn difficult, in VMC or IMC - it makes no difference.

Your point is a good one, but I think you exaggerate. Flying IFR in VMC can indeed be "pretty damn difficult" in some circumstance, but handflying a light aircraft in IMC undoubtedly adds to the workload, otherwise we wouldn't bother with those pesky screens and hoods for practice. IMC also takes away the safety net of seeing the obstacle before you hit it.

Where there is a big difference for a relatively inexperienced private pilot is that, unless practising, he will be flying an approach for real, with few of the toys that Sick Squid has at his disposal, and the pressure will be on. He may be disorientated, worried and distracted by even a small equipment failure. Add in night and poor weather, slight traces of icing... We owe it to him to ensure he is trained to do it. If his training is less than that of an IR, then to higher minima.

I think one of the points IO540 is making is that to force the pilot to fly at low level and deprive him of an air traffic control service because the airspace above him has the wrong letter attached is hardly going to make his job any easier. Yet the difficulty of flying IFR for IMC-rated pilots tends to be increased by the airspace class restrictions. To fly IFR with an IR is usually considerably easier than what they have to deal with, as we have more levels available and more ATS help. That is yet another reason why a reduced-privilege instrument qualification must not be arbitrarily restricted by airspace class.

And I have reservations about any restriction being based on IAP minima. A couple of hundred feet vertical buffer sounds as if it's a concession to inexperience, but is unlikely to save the poor overloaded pilot who turned the wrong way at the fix, misread the platform altitude from the plate by 1000 ft, selected the wrong VOR (these days I guess it's "flew towards ABAMO rather than ABUMO"), or misheard the ATC clearance and failed to check the MSA. The vertical tolerance with which one flies a profile has a lot more to do with currency and experience than the amount of training one received 10 years ago at an approved organisation.

[Keef]

A private pilot would not depart IFR with no AP.
Sorry to disagree, but: Yes, I would. I often do. It hones the handling skills.
It also tests how well I've prepared the stuff I can prepare, and how well I cope with the unexpected.

Whether or not I shouldis a different question. My IMCR instructor, many many years ago, taught me to use all the equipment available, but to fly with whatever's there - as long as it meets the minimum IFR requirements.

So I do. I flew the FAA IR checkride, at night, in an Archer with no A/P. It was a long session, too, as that checkride is.

[Fuji Abound]

A couple of hundred feet vertical buffer sounds as if it's a concession to inexperience, but is unlikely to save the poor overloaded pilot who turned the wrong way at the fix, misread the platform altitude from the plate by 1000 ft, selected the wrong VOR (these days I guess it's "flew towards ABAMO rather than ABUMO"), or misheard the ATC clearance and failed to check the MSA.


There is a choice to be made between Mr Thorpe's idea of pilots climbing through an overcast (hopefully, but not necessarily, into VMC) followed by a descent before their destination in the hope that they will safely achieve a cloudbreak and achieving VMC on an IAP but with a greater buffer minima than IR holders.

That choice will have to be made unless Mr Thorpe proposes that an EIR holder may only depart if his destination is VMC. If that becomes his proposal then we may as well all give up on this one.

I accept there are some airports were there is less margin for error because of either the complexity of the IAP or the terrain. That is why I proposed the airports have the authority to make certain approaches or certain airports unavailable to pilots with an EIR.

It should be remembered a great many airports with IAPs have radar which inevitably provides a degree of protection from pilots making turns in the wrong direction.

My proposals are commensurate with the needs of private pilots who do not wish to hold an IR, whilst providing the EIR holder with additional protection during the most dangerous phase of IF, whilst keeping the pilot on the same hymn sheet as everyone else in the system rather than making up his own procedures - I commend these proposals to you.

[FREDAcheck]

And I have reservations about any restriction being based on IAP minima. A couple of hundred feet vertical buffer sounds as if it's a concession to inexperience, but is unlikely to save the poor overloaded pilot who turned the wrong way at the fix, misread the platform altitude from the plate by 1000 ft, selected the wrong VOR (these days I guess it's "flew towards ABAMO rather than ABUMO"), or misheard the ATC clearance and failed to check the MSA. The vertical tolerance with which one flies a profile has a lot more to do with currency and experience than the amount of training one received 10 years ago at an approved organisation.
That makes sense, and another mistake for less experienced pilots is probably "wrongly set QNH". But restrictions on minima would be enough in some cases, I would have thought. For those requiring accuracy for obstacle clearance, or busy ones where volume of traffic would make wrong turns more than usually hazardous, they could simply make the procedure "no EIR".

[bookworm]

My proposals are commensurate with the needs of private pilots who do not wish to hold an IR,

Sounds to me like that's exactly what they do wish to hold... ;)

[IO540]

Sorry to disagree, but: Yes, I would. I often do. It hones the handling skills.As often, I don't write an essay on each point :)

It depends on the flight.

If I was flying from say Goodwood to Southend, OVC008 at each end, and done mostly at 2400ft as one does in that area, I would not be worried. In fact I would probably not use the AP, because when flying "real IFR" one spends so much time in VMC that one doesn't get enough hand IMC practice. On my last big trip (Turkey LTBH via LDSB, and back via LGMT, LDSP) I logged about 30hrs I think and barely a few minutes "instrument flight", which is not unusual for high altitude IFR with an appropriate icing strategy.

I think that when flying IFR/airways one should aim for the most professional conduct, which means flying accurately and generally being on top of things w.r.t. ATC etc. This means making best use of cockpit automation. The place to practice hand flying stuff like NDB holds is in Class G, at 5000ft where few in UK GA have ever ventured, out of the way, in real cloud, and one can do them over and over without anybody else caring. I do that about once a week on little local flights. That is also the place (with the 0C level being no lower than 2000ft) to see how much one's IAS drops versus the thickness of the ice picked up ;)

But a flight from Goodwood to Prague, IFR, with a duff AP? I would not go. I would get the AP fixed. I would not accept the reduced safety of the increased workload. I would go with a co-pilot (and indeed I have done more or less exactly such a flight with a co-pilot a year ago, when a replacement for a failed pitch servo had not yet turned up from the USA).

Another reason I would not generally fly for real with an INOP AP is that unless the fault is positively diagnosed, one cannot be sure there isn't a latent defect in the electrical system which is actually not limited to the autopilot system. This is a much wider safety policy issue and is why I don't like flying the old GA training scene wreckage which is often covered in INOP stickers. Is such and such item INOP because the specific piece of kit is duff, or because a wiring harness is slowly getting cut through / shorted out against a bulkhead? A lot of defects are left undiagnosed due to working under the cost pressure of a typical FTO owner. Unless somebody chased down the defect, you just don't know, and "not knowing" is a no-go for me.

[Fuji Abound]

Bookworm


Sounds to me like that's exactly what they do wish to hold...


That seems a very strange remark for you to make?

What would you propose and why?

[bookworm]

What would you propose and why?

I would propose:

* that those who wish to fly IFR should get an instrument rating

* that the training requirements for the IR should be proportionate to the real needs of instrument flying (as apparently proposed by FCL.008) rather than being needlessly costly and time-consuming

* that the standards for IFR flying should remain single tier and universal

* that any sub-ICAO instrument qualification is considered not as an end in itself but as a stepping stone to an IR, in the same way that student solo flight is considered a stepping stone to a PPL (or CPL/ATPL).

On the last point, I remain encouraged that such a stepping stone is possible, but I don't feel too attached to the idea that it has to be the Enroute IR that FCL.008 has discussed. I have not, however, seen a proposal that convincingly balances privileges and training of any such sub-ICAO rating.

[421C]

In JARland we expect our 200 hr C152 and 50 hr SIM pilots to be capable of commanding a 747 as captain under instrument conditions? That is nuts, which is where the FAA 1500 hr ATP minimum and test (and as was the Norwegian system and I believe the UK system too in the old days) makes complete sense. Why not revert the EASA ATP back to that and get rid of this "frozen" ATPL nonsense.

I think (with respect) you've misunderstood the differences between the two. The JAA IR is not the JAA world's equivalent of the FAA ATP checkride. The equivalent is the Type Rating in a Multipilot Aircraft (MPA TR) you need to get, after an MCC, in order to qualify for a JAA ATPL. It's pretty similar to the FAA system, where every Type Rating is done to ATP standards, but under the JAA there is no ATP checkride you can do in a light piston aircraft, but you can do your final ATP checkride (the MPA TR) before you qualify for the hours.

Our 200hrs C152 man has to pass a type rating on a 747 (amongst other things) before he can command one! The private and commercial routes diverge after the JAA IR, not before it.

This way we wouldn't have to have a gold plated JAA IR as the only option.As tempting as it is to assume the JAA IR is the "ATPL gatekeeper" it simply isn't. The ATPL writtens, the 1500hrs and 500 multicrew and the MPA TR are the 'gatekeepers'.
Incidentally is it gold plated or not or just anal? On his test / 170A my mate had to "dead reckon" his way to ORTAC on some departure from Gurnsey despite having a fully functional G430 in the aeroplane. That is just plain stupid. Neither. The "dead reckon" to ORTAC is just being practical if RNAV is not used. It's quicker than intercepting the radial from the GUR. The fact RNAV isn't used is more down to the schools than the CAA; many do not teach the use of GPS because it would add more workload to the course. The use of GPS and Autopilot are already perfectly acceptable in the JAA IR; it's just that single needle tracking of radio aids and hand flying also have to be demonstrated. So schools focus on the parts likely to catch students out, not the relatively easy parts.

My understanding is that from Jan 2010, there will be a change in policy from the CAA IR Examiners, to permit GPS approaches as the NPA on the IR and to reduce the single needle enroute and approach work. I saw a letter in an FTO and don't remember the details.

There is very little difference in content between the JAA and FAA IRs. There's a lot of difference in training processes and structure.

I calculated yesterday that for me to convert to the IR it would cost me £1000 for the ground school, and then abut £500 for the exams, plus the examiners fee of £700 - and that is before one bit of flying. Unless this changes then an IR will be no more accessible than it is now.
I doubt if anything is going to get materially more accessible than the already pretty reasonable FAA to JAA IR conversion. You don't need a formal course of ground training, you just sit the written exams for the costs you describe. Then its 10 Sim Hrs and 5 Aircraft hrs (or all in your own aircraft if you prefer) plus the exmaniner fee. What really hikes the cost is the 50hr initial course for people who don't have an ICAO IR; the relatively small number of FTOs around can also be very inconvenient. Under EASA, the RF vs FTO distinction will disappear - they all become ATOs. The written exams will probably get cheaper and dragged into the late 20th century in terms of computer testing at independent test centres. All IREs, rather than just CAA ones, will be able to conduct initial IRs.


I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.

The problem is that you see it as an "EIR with precision approaches" and EASA will see it as an "IR without non-precision approaches" and conclude that course needs to be pretty much like the current IR with a few bits trimmed. They are not going to say "good lord, without NPAs we can make it a totally different training model". And if you are going to do all the exams and training and take the test, why not include the one NPA flown on the test and get a full IR?

[Fuji Abound]

Bookworm

You should be very careful what you wish for.

If you are not careful you will get the promise of a more relevant IR, period.

That would be the worst thing that has ever happened to GA in this country - and I refer intentionaly to this country because as much as I support the EC people on this thread are concerned about what happens in their backyard.

At least even FCL008 realises there is a need for an intermediary IF rating and are in step with "modern" thinking. Modern because the Australians are the only country in recent times to have overhauled FCL and they effectively went exactly that route.

Clearly we are much further apart than I thought, sadly.

[Fuji Abound]

and if a simplified IR were really come to pass, in the end few would bother with the IMC rating or EIR so what does it matter if you introduce these during the transition? I bet if you introduced and EIR or IMC rating in FAA land no one would bother with it, BUT they have a realsitic IR.

The trouble is you will be promised one and get neither. Go figure.

[FREDAcheck]

bookworm, I'm afraid I have to disagree with you.
* that any sub-ICAO instrument qualification is considered not as an end in itself but as a stepping stone to an IR, in the same way that student solo flight is considered a stepping stone to a PPL (or CPL/ATPL).
That really isn't what most IMCR holders are looking for. For them IMCR isn't a stepping stone to anything except exercising the privileges of IMCR.

Saying that IMCR holders fall into two groups: those that really want IR, and those who want to cope with accidental IMC, simply isn't true. Sorry to be so blunt, but it's a mistake to try to wish away any requirement for IMCR by imagining people really want something else (or would do if only their eyes were opened).

I'm well aware of the hostility to IMCR or any sub-ICAO instrument qualification, but really: the IMCR is what is wanted to fill a substantial need among PPLs.

It absolutely won't meet the need to have an accessible IR and quietly trash the IMCR.

[Keef]

Things are getting awfully "black and white", and inappropriately so in my view.

I'm a defender of the IMCR, and will be exceeding miffed if it disappears with no replacement. However, if EASA came out with a "halfway house" IR that was very like the IMCR (but different) - I wouldn't be yelling "NO WAY". I'd be wanting to know more about the details.

The EIR as defined - with no IAPs - doesn't cut it, I think we agree. Not even as a "stepping stone to the real IR". I think that message has been communicated. I hope it's been understood.

Anyone who can pass the IMCR written can, with a bit of application, pass the FAA IR written. Take that as the "benchmark". EASA say they will simplify the IR written: I'd like to know more about what that means before I reject it out of hand. If it's just "tinkering at the edges", they know what the reaction will be. If it's something very like the FAA IR (ie totally relevant), the reaction should be positive.

I remember when I did my FAA IR asking the instructor "is this the same IR that the ATPL flying a 747 has?" His answer was "Question is irrelevant." He explained that it's the same IR "on paper", but that the ATPL checkride tests IFR capability all over again, and the test standards are higher. If you have an FAA ATPL, he said, effectively you don't "need" an IR because the IR is included - and to those higher standards.

From memory, the checkride standard was for example "maximum of half scale on the localiser/glideslope" for the IR, and "quarter scale" for the ATPL. Those may be wrong, but that was the principle.

I took and passed the FAA IR after self-study and the "recent training hours with an FAA CFII". The other hours required by the FAA were obtained from the IMCR course I did all those years ago, and the hours I'd built up flying around the UK using the IMCR. It was a logical, challenging but achievable process.

Had I had a CAA IR, the requirements to get an FAA one would have been minimal. Sadly, the UK CAA regards (or regarded, I dunno) the FAA IR as being sub-ICAO in some way and won't return the compliment to the FAA. They required me to do the whole academic bit, more training, and then the full flight test. Fair enough on the flight test, maybe on the training, but rhubarb on the study. So I didn't do a CAA or a JAA IR.

My hope is that EASA will recognise and deal sensibly with the safety need for an achievable IFR qualification for PPLs and other non-ATPL types (as the FAA did) and disregard the vested interests that want to preserve the present jumbo mumbo-jumbo. I don't think many on here disagree with that. Or I hope that's so.

[flybymike]

Can I suggest you urgently engage an aviation lawyer (the Flying Lawyer aka Tudor perhaps?)

I believe Tudor is a Circuit Judge these days, and don't imagine he could become involved even if inclined.

[bookworm]

Saying that IMCR holders fall into two groups: those that really want IR, and those who want to cope with accidental IMC, simply isn't true.

You're right, FREDAcheck. There's also a group who want to exercise the privileges of an IR but are not prepared to demonstrate their competence to do so by going through a training and testing process that is proportionate to the privileges of the rating. They claim that they "don't need an IR" by striking off privileges that they mistakenly believe differentiates what they do from what instrument rated pilots do. But, probably since most of them have not held IRs, they actually expect to be allowed to perform most of the hardest flying tasks expected of an instrument rated pilot and still be exempted from the training and testing framework that will be put in place for FCL. And I fear they will be disappointed.

[IO540]

One thing which needs to be appreciated is that to fly around Europe in controlled airspace under IFR, one needs more than an "IR".

One also needs an appropriately powered and equipped plane. The minimum altitudes at which one can file Eurocontrol routings are about FL070. However in many areas FL070 results in a terribly roundabout routing and FL100 is where it starts to be viable. FL120 is required in many places to avoid big doglegs. FL140 is pretty good, and is the minimum to cross the Pyrenees. FL160 is required to cross the Alps. There is a lot of detail I am leaving out here (like minimum LTMA overflight levels being about FL100 plus) but basically that is the picture. The routes cannot generally be worked out from an airway chart; one has to use special routing tools to develop them.

So you need a capable plane, very preferably with oxygen, etc.

Above FL095 (and airways routings don't work well below that in many places) the only legal means of navigation (in GA context) is an IFR BRNAV approved GPS installation.

Mode S of course, everywhere.

I don't think many people have access to this level of equipment. In general you will be an owner, or in a reasonably upmarket syndicate. Then there are the Cirrus "zero equity" rental groups, etc. but they are far from cheap.

There is also a significant amount of technical/operational knowledge, much of which isn't taught anywhere. But that's another story.

The IMCR, with its restrictions, suits an awful lot of casual flyers/ renters very well.

The IMCR training is also generally used towards the FAA IR, although last time I wrote about this I got hit with a filthy libellious and widely circulated email alleging flying on a fake IR etc. In practice this is usually moot as almost everybody reaching the FAA checkride standard will have done the whole FAA 15hrs dual time in the USA with an FAA instructor - myself included :)

I think most FAA IR holders started life as IMCR holders and this enabled them to do an awful lot of instrument practice on their own, which is much more relaxed as well as cheaper than flying with an instructor as one would for 50-55hrs for the JAA IR. So even if they did not strictly speaking use their IMCR training time towards the FAA IR's 15hrs requirement, they still saved a big pile of money. By the time I went for the FAA IR, I had a bigger part of 100 instrument hours already.

[mm_flynn]

One thing which needs to be appreciated is that to fly around Europe in controlled airspace under IFR, one needs more than an "IR". ....
IO,

I think you are painting an overly complex picture of IFR in Europe. Certainly over the Alps and Pyrenees you need to be able to reach O2 levels to be safe. However, there is a reasonable amount of 'Near Europe' that is nearly as benign as the UK from a terrain perspective. Some of those countries have a similarly relaxed attitude towards DCT routings as the UK - and even better, have not designed their airways around turbine routes! In these countries any reasonable aircraft can be an IFR platform.

The UK is unique in its approach to IFR (in that about the only rule in IFR is 1000 ft above the ground, if you can't see it, unless you are trying to land (there are others but they either exist implicitly in the V rules or are recommended but not obligatory for Visual flight), as such it does help create this view of pilots than 'I am VFR but am in IMC' and that IFR is what people do up high on Eurocontrol routes.

It is actually quite enjoyable to be able to duck through clouds without the overhead of an ATC clearance/routing, but it is a concept totally out of synch with the rest of the world.

[IO540]

Yes, I agree but I was referring to the airway MEAs rather than terrain. Most European airway MEAs are set by ATC rules / airspace classification and bear no relation to obstacle clearance, and this is especially so in the UK.

[Fuji Abound]

There's also a group who want to exercise the privileges of an IR but are not prepared to demonstrate their competence to do so by going through a training and testing process that is proportionate to the privileges of the rating.

and you base that spectacular assertion on what evidence?

It is most unlike you Bookworm to be carried along by emotion, you should stick to the facts.

I think whatever Europe does it is quite insulting to IMC rating holders who have taken and passed a series of tests laid down by the legally appointed regulatory authority and then imply that they have not demonstrated their competence.

THEY have!

You may not like it, you may disagree with the IMC rating, but doubtles there are more than a few who would disagree that the IR standard is proportionate. Simply because you believe one standard is more proportionate than another has little to do with reality unless you can base your assertion on evidence rather than getting carried away by your emotions.

I might just as well say I think your IR is worthless because the test and training is hopelessly out of step with whats needed to fly in controlled airspace in Europe in a light sinlge.

Anyway we shall just have to see. There is a democratic process to be followed. You can bet we havent heard the last of this. You can also bet that a lot of pilots will not simply roll over and accept the outcome unless it is proportionate. :}

I am done for the time being because we are just going around in ever decreasing circles without any ambition by many to address the real issues.

[bookworm]

I think whatever Europe does it is quite insulting to IMC rating holders who have taken and passed a series of tests laid down by the legally appointed regulatory authority and then imply that they have not demonstrated their competence.

And I've done nothing of the sort. I've repeatedly said that I believe that group of IMC-rating holders, who use their ratings to plan and execute IFR flights which would require IRs in any other country, are perfectly capable of demonstrating their competence to do so by taking and passing an IR skills test. What puzzles me is why they are so adamant that they shouldn't have to.

[Fuji Abound]

I did say that was my lot but reluctantly:

Come on Bookworm you know exactly why they would say that, you are just being mischevious.

I wonder how many IR holders could pass an initial IR check ride - and indeed why they would want to. I know I probably couldnt if I turned up tomorrow claiming I was a first time student and wanted to take the test.

Moreover, you know full well the check ride for the IMC rating is different to the check ride for an IR and presumably the check ride for an EIR would be different again. The check ride for an FAA IR is different from a JAA IR, and doubtless different from an ICAO IR check ride in outer Mongolia.

I recall many years ago I turned up for an IMCr renewal with a different instructor. The fella had an IR. He asked to see my PLOG and expected to see all the freezing levels calculated, W and B, and half a dozen other matters which were complete nonesense. (It was August and we couldnt have reached the freezing level if we spent all day trying). I went round the corner as they say to a chap who didnt have an IR but had 100 times the experience of our latter day saint.

[Katamarino]

I think a big reason that many IMC holders would not wish to go ahead and 'demonstrate their skills' to get an IR currently, is the sheer amount of unecessary money to be sent to the numpties at Gatwick for doing...pretty much nothing. 700 pounds for the privelige of taking a short examination? The CAA certainly monopolise their way to impressive hourly rates for sitting on their arses and trying to stop us from flying!

What do they even do nowadays? All the recent times I have sent them questions, I've received the reply 'we don't know, ask EASA'.

[IO540]

I may be missing something obvious here but I don't understand why UK IMCR holders should be required to pass an IR checkride to continue exercising their IFR privileges in the UK.

If they wanted to exercise them in say Germany then it would make sense. In Germany you play by German rules, etc.

Anyway, the vast majority of UK flight on IMCR privileges is going to be OCAS and thus falling outside of the remit of any regulatory authority to dictate the individual's attitute to risk.

I don't know if I would pass a JAA IR checkride today; probably not... depends on how much raw data single-nav-instrument stuff is involved.

[BEagle]

There are 2 main ways ahead:

Either to develop an IMC rating (or whatever you wish to call it) which everyone else in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.

The whole 'my Rating is better than yours' nonsense needs to stop. Whether people want an IMC rating or an IR should be up to them; personally I wouldn't ever want to fly a spamcan on European airways, but others might.

It came as an obvious surprise to M. Sivel to learn that, whereas an FAA PPL IR holder is never retested, an IMC rating holder has a mandatory re-test with an Examiner every 2 years.

Presumably the PPL/IR Europe group consulted those of its members who only hold IMC ratings to elicit their opinions before presenting its opinion through the EAS delegate on FCL.008?

[IO540]

Either to develop an IMC rating (or whatever you wish to call it) which everyone else in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.

I think the options are

Either to develop a more GA-accessible ICAO IR which everyone in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.

The reason for the "ICAO IR" is that there is zero chance of European acceptance unless one has equal in-flight competence with IR pilots. There is room to play on what constitutes applicable/relevant theory, where the training is done, etc (and FCL008 appears to have done some of that) but there is no room to play on in-flight competence which basically means an identical checkride, plus ICAO minimum training compliance which is no big deal at just 10 hours.

Sub-ICAO, any country can do what it likes but the EU position is that this is not allowed.

Australia has its own "IMC Rating" kind of thing but Australia is not in the EU (very wisely :) ).

[BEagle]

No, the so-called 'accessible IR' is a different issue. I am talking purely about the IMC rating.

People should STOP saying what is or isn't 'ever going to be acceptable in the rest of Europe' - the question is more basic. Do you or don't you want something in Europe which gives identical privileges to the UK IMC rating - which you can use where the airspace authorities allow?

Incidentally, I hear that there is considerable resistance to the 'accessible IR' from airline pilot unions - they want less spamcans in 'their' airspace, it seems. Having listened to the stumbling incompetence of a 'continental' PPL/IR holder trying to fly an approach at Bournemouth once, I do see that they may have a point.

The Australian PIFR developed from the original Australian 'EIR' proposals and now include Flight Procedure Approvals (e.g. instrument approach procedures) after completion of additional training and testing requirements......:rolleyes:

[IO540]

Incidentally, I hear that there is considerable resistance to the 'accessible IR' from airline pilot unions - they want less spamcans in 'their' airspace, it seems.

There are virtually no spamcans in "their" airspace already. There aren't be - they can't climb high enough. I have flown IFR to some far corners of Europe and have almost never seen another GA plane. All one sees is a load of contrails at FL300...

Having listened to the stumbling incompetence of a 'continental' PPL/IR holder trying to fly an approach at Bournemouth once, I do see that they may have a point.

That is a very small data sample.... You can find d1ckheads in any discipline.

[bookworm]

I wonder how many IR holders could pass an initial IR check ride - and indeed why they would want to. I know I probably couldnt if I turned up tomorrow claiming I was a first time student and wanted to take the test.

The "initial IR check ride" as you put it seems to be an artifact of the gold-plated IR as a gatekeeper to professional licences. EASA seems to have rejected any notion of examiners being delegated by an NAA, let alone them being employees of the NAA. Examiners will be individually certified and monitored by EASA. To presume the double standard of testing that you imply is, of course, in line with your presumption that there will be no change in the training requirements for the IR. I think you underestimate the EC's and EASA's commitment to change.

[Fuji Abound]

Bookworm

Well, I have enjoyed the debate with you and everyone else. Thank you.

There have been some very good points made (from both sides of the fence).

The one thing about which none of us can be entirely certain is what will actually come out of EASA. They have the opportunity of rewriting the rule book which does not come along very often. Either they will grasp that opportunity and really produce a worth while change or they will fail in their mission.

As I think I have made very clear the early signs are not very good. To be fair they have not been helped by co-opting advisors who clearly wouldnt know and IMC rating if they flew into one (as but one example). As is so often the case with this sort of process if you are hijacked by all the usual bad eggs before you even get started dont be surprised if you end up with a result they wanted but no one else did.

Rather like an episode from Yes, Minister, if you co-opt the "right" people to any committee you can get whatever result you want. What is far more dangerous is when you dont really know what result you want so you put people in charge who havent got a clue, other than their own interests. Then the lunatics are really running the asylum

Anyway, that really is me done.

We shall just have to wait and see.

I have no doubt we will return to the debate when there are any more developments.

What I have found interesting is there are some contributors to this thread that I would have had on my committee before the thread started and would not now, and others for whom the reverse very definitely applies. It does at least just show how difficult it can be to get the measure of people.

(I know thank goodness it is not my committee, hat, coat etc. :})

[BEagle]

I hear that the latest edition of Pilot will put le chat amongst les oiseaux....:eek:

[Justiciar]

This whole process is of course nonsense, born out of a desire to "harmonise" everything, which in turn comes from the continental habbit of being unable to trust anyone else to get things right, in this case the individual countries of europe, without pages of regulation. They are re-inventing the wheel, as of course we have already a perfectly good set of international standards, called ICAO. JAA added little to what ICAO offered and EASA will be similar. As each country already allows holders of ICAO licences to fly the aircraft from that country in another's airspace the EASA licensing will add little beyond allowing the national of one country to fly another country's aircraft in that airspace.

As all countries of the EU should be assumed to be able to train their nationals in accordance with ICAO there is absolutely no benefit to the ICAO process which cannot be addressed by simply ensuring mutual recognition of national ICAO standard licensing within the EU. Anything sub ICAO can be left to the discretion of the country concerned (wasn't that what we had about a thousand years ago, until JAA came along!).

There we are, problem solved. I can't see what the fuss was about :ugh:

Sooner or later this country has to say enough is enough (I happen to notice the other day a quote from the EU that the cost benefit of the single market to business in the EU is about £160 billion; the cost of compliance with the rules is £600 billion :{).

[BEagle]

I note that the President of European Air Sports has now stated (my bold text for emphasis):

We have a published guiding principle which our members endorsed some years ago with the advent of EASA, which is 'The guiding principle for the transfer of governance from national authorities to a European authority should be: “what is permitted and conducted safely today in individual countries should continue to be permitted under the new regime." '

I guess that guiding principle covers the point quite well as regards the IMCr. The stance we have taken is that we support the retention of the IMCr in the UK, and if it is possible to negotiate its wider acceptance beyond UK shores we shall do so. Equally however we have been active over several years in Europe in pressing for a more accessible IR compared to the present JAA IR. Hopefully that will be one of the final outcomes of the work that has been going on this last year.

This is a most welcome statement. EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%. One must thus query why the EAS delegate on FCL.008 does not appear to have presented his own organisation's clear policy in repsect of the IMC rating.

Since AOPA (UK) knew that EAS supported the continuance of the UK IMC rating, it was hardly unreasonable for AOPA to expect that this EAS policy would be presented at FCL.008 by the EAS delegate.

This all supports the point I made to Eric Sivel last week; clearly the FCL.008 group did not represent stakeholder opinion, hence the data EASA now has from them is fundamentally flawed and should be firmly rejected.

[Justiciar]

what is permitted and conducted safely today in individual countries should continue to be permitted under the new regime

The quote should perhaps have been: "..... should continue to be conducted by individual countries".

Like many things relating to Europe, this is a very expensive solution looking for a non existent problem. Even the Commission suggested this recently when it told EASA to stop re-inventing the wheel. The principle of individual licensing regimes set to an international standard is so well established that it is difficult to see what this process is adding to either cost or safety, since non EU countries' nationals will continue to fly in EU airspace using their own licences. The continuation of national licences and ratings will have a zero impact on the single market so what is the entire process about? What it is about is Europe getting its fingers into every aspect of national life, asserting itself at the expense of individual countries.

If they wanted a sub ICAO sport pilot licence (whatever you choose to call it) then they should have focussed on that and simply validated national ICAO licences across the whole of Europe, which could be done so simply and cheaply compared to this bureaucratic gravy train which is now rumbling along gathering speed.

[IO540]

EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%

The only way to dig up 320k pilots in Europe is to count every lawn mower including the one in my garden shed, and every parachute :)

since non EU countries' nationals will continue to fly in EU airspace using their own licences

It gets even better because the EASA FCL proposal uses the word "residents" not "nationals" :) The latter is the ICAO option, which I believe means citizenship. The whole thing is bizzare.

[David Roberts]

Quote:
"EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%
The only way to dig up 320k pilots in Europe is to count every lawn mower including the one in my garden shed, and every parachute"

But if you look at the list of the sectors of light aviation in my posting 'elsewhere' (I tried to avoid posting the same in two places) you will see that EAS's membership constituency isn't just aeroplane pilots i.e. the sector debating the IMCr / IR. It covers a much wider range. For example, there are approximately 85,000 glider pilots (with a club and private glider ownership of c. 22,000 aircraft) in Europe, who through their national gliding associations are members of the European Gliding Union which is turn is a member of EAS. The same principle applies to hang glider pilots, microlight pilots, parachutists etc. There may of course be some double-count in the c. 320k referred to as some people are active in more than one sector, but that doesn't alter the figures materially. Fortunately (from one point of view) many of our constituent members are not affected by EASA as they operate Annex II aircraft, and remain, for the forseeable future at least, under national regulations. The ones that are affected by EASA are aeroplane pilots / owners, gliders, balloons and helicopters in categories > the Annex II threshold.

[Timothy]

BEagle,

You said on Saturday that you were going to grow up, stop the sniping and work towards a united approach.

Can you just not help yourself? :}

[BEagle]

Timmy old thing, do please stop being so unreasonably offensive.

David Roberts has kindly put the record straight and has made the official EAS viewpoint very clear. That is to support the continuance of the IMC rating.

It is hardly unreasonable to expect an EAS delegate at FCL.008 to promote the EAS viewpoint, just as the IAOPA delegate promoted the IAOPA viewpoint. My question is simply "Why didn't he?".

[Fuji Abound]

You said on Saturday that you were going to grow up, stop the sniping and work towards a united approach.

How did you get on?

Beagle and David

I am very glad you asked and David has clarrified his position. I have to say that I was very uncomfortable where David stood - all credit to him for giving such a clear explanation and more importantly having the courage to enter into the discussion on this forum in the first place. It is a shame we do not see some of the other "players" so willing to subject themselves to public scrutiny. I take my hat off to David for having the courage of his convictions to engage with people on this and other forums. Thank you Dave.

That said, I would still like to know whether David sees the stance taken by Mr Thorpe as being compatible with position he now sets out and why he feels Mr Thorpe choose to publish his review of the work of FCL008 on PPL/IR rather than else where.

[BEagle]

Fuji, you are probably confusing meetings. Timmy's quote has nothing to do with our EASA meeting.

At the meeting AOPA et al. had with Eric Sivel earlier in the week, I made it abundantly clear that, in my opinion, the final FCL.008 memorandum did not represent stakeholder opinion with regard to the IMC rating. That has now been positively confirmed de facto by David's statement.

It is clear that both EAS and IAOPA both support the UK IMC rating.

Unfortunately there are some individuals who continue to obfuscate and to throw smearing allegations at others, whilst making no worthwhile contribution of any material benefit whatsoever themselves. Sad, but true. But they can, of course, be ignored. And should be. I'm not a bible-basher by any means, but Matthew 7 vv3-5 spring to mind:

And why beholdest thou the mote that is in thy brother's eye, but considerest not the beam that is in thine own eye? Or how wilt thou say to thy brother, Let me pull out the mote out of thine eye; and, behold, a beam is in thine own eye? Thou hypocrite, first cast out the beam out of thine own eye; and then shalt thou see clearly to cast out the mote out of thy brother's

Whether EASA comes up with a so-called 'more easily attainable PPL / IR' is nihil ad rem. What is of much greater importance is that the UK IMC rating must continue to be acceptable in UK airspace, at the very least.

[Fuji Abound]

Whether EASA comes up with a so-called 'more easily attainable PPL / IR' is nihil ad rem.


I think it could be to the point. If an IR was on offer that in terms of cost, relevance and convenience was not a million miles apart from the IMC rating then the gap may be a far less of a concern.

No, I hadnt that meeting in mind.

[Pace]

What is of much greater importance is that the UK IMC rating must continue to be acceptable in UK airspace, at the very least.

Beagle

That is very unlikely to be in question! Its not the least which will be the lost opportunity but the most. The most without doubt will NOT be a European IMCR.

Pace

[bookworm]

I'm not a bible-basher by any means, but ...

I'm not either, but I've always admired the prayer attributed to Oetinger:

"give us serenity to accept what cannot be changed, courage to change what should be changed, and wisdom to distinguish the one from the other" ;)