IMC Rating - Latest Update

[Mike Cross]

AOPA UK has been given a chance to counter some of the misinformation surrounding the UK’s IMC rating at a special meeting with representatives of EASA, EASA’s FCL008 Working Group, and the UK CAA in Cologne on October 5th.

Two AOPA representatives have been invited to the meeting – Chief Executive Martin Robinson will go, along with Nick Wilcock of the AOPA Instructors Committee. Exactly what form the meeting will take has not been clarified, but at some point – and for the first time – AOPA UK is expected to be given the opportunity to make the case for the IMC rating, and to propose how it may be continued in the UK even after Europe-wide harmonisation.

Full story here. (http://www.joinaopa.com/index.php?option=com_content&view=article&id=249:eleventh-hour-bid-to-save-the-imc-rating&catid=1:latest-news&Itemid=247)

[flybymike]

Godspeed.
Let's hope they make a better representation job than the PPL IR delegate...

[Dan Winterland]

I wish them the beat of luck. In my opinion, the IMC rating has always been the equivalent of an "A Level'' in flying after the "GCSE" PPL and is a natural progression to maikng a safer, more knowledgeable and responsible pilot - regardless of whether it is used in anger or not.

It was heavily promoted to the pilots at one club I instructed at - a club with exceptional standards and an enviable safety record. I won't mention who the CFI was, but he's going to this meeting!


I hope this thread developes into a meaningful discussion. I know one of the chaps will be reading it and it may give him some moral support, and maybe some ideas for the case.

[wsmempson]

how did yesterday's meeting go?

[Pat Malone]

This brief update from AOPA



At a special meeting of EASA, members of the FCL008 Working Group and the UK CAA called in Cologne on Tuesday to discuss the UK IMC rating, EASA agreed as a first step to “grandfather” IMC rating holders for life – which means anyone who gets the rating before EASA takes over responsibility for licensing in April 2012 will be allowed to fly safely under its provisions for as long as they live. AOPA UK, which was invited to an FCL008 meeting for the first time, welcomed the decision but will continue to press for the retention of the IMC rating in order to protect the next generation of pilots as we protect ourselves. In this, AOPA has the support of the UK CAA, which sent its Head of Licensing and Training Policy Cliff Whittaker to join its representative on FCL008, Mike Dobson. Together they made it clear that it is CAA policy to retain the IMC rating. EASA also sent some big beasts to the meeting, including Matthias Borgmeier and Eric Sivel from the Rulemaking Department. EASA’s Notice of Proposed Amendment covering instrument flying is due in January 2011, at which time the precise details of its intentions on the IMC rating will become known. Martin Robinson and Nick Wilcock attended the meeting on behalf of AOPA UK. Afterwards Robinson said: “We welcome the concession, having previously been told it was not possible to grant grandfather rights under EASA, but we will not allow it to take the steam out of the campaign to retain the IMC rating for the safety of all UK pilots present and future.”
A fuller report on the meeting will come from Nick Wilcock shortly.

[Fuji Abound]

Pat - that is really great news, and at least one step in the right direction.

It just goes to prove that all those who said the IMCr was dead under EASA and there was no scope for national exceptions were wrong.

Lets hope that is not all they were wrong about.

[Dave Unwin]

I sincerely hope I'm wrong, but the eternal cynic in me remains very sceptical.

[IO540]

That is absolutely amazing - but of course if they can leave the Rating valid for life of existing pilots, despite a thousand EASA rules saying this is impossible, then it can remain in place for all the future ones too...

[BEagle]

AOPA has taken the view that 'Grandfathering' is possible under the terms of para 5 of Article 4 of the Cover Regulation (Agency Opinion to the NPA 2008-17b Comment Response Document):

5. The scope of the privileges given to pilots whose national pilot licences, including any associated ratings, certificates and/or qualifications are converted into Part-FCL licences and associated ratings or certificates should at least cover the scope of the activities that the pilots are undertaking at the date of entry into force of this Regulation, provided that the safety level is not affected.

This is not the same thing as 'national exceptions'.

However, extending matters beyond this is more difficult for the €urocrats to accept. One recommendation which will be presented to them is the facility to permit Member States to issue 'restricted' IRs with restrictions decided by the Member State in which the IR is intended to be used. Thus in parts of €uroland the 'restricted' IR would be identical to the so-called 'EIR' and in others (such as the UK), the 'restricted' IR would be the UK IMCR by another name. This would also EASA to fulfill the assurance they gave both to the UK CAA and, more significantly, to the European Parliament, in respect of the future of UK IMCR privileges.

When the NPA is released, it is important that individual comments - and emphatically not orchestrated comments - are made. The more the merrier! But if EASA has any sense, then it will ensure that the NPA is as uncontentious as possible by drafting it appropriately in the first place.

[Pat Malone]

BEAgle:
You're absolutely right in urging everyone to make individual comments when the NPA is released in January. Rarely will a united, large scale response be as important.
The grandfathering issue is not something AOPA has taken a view on; they were as surprised as the CAA representatives when EASA made the grandfathering offer. AOPA has previously been told by both EASA and the CAA that grandfathering was not possible under EASA. As Eric Sivel said to Martin Robinson at Duxford at the AOPA Open Day (while rolling his eyes) "With EASA, anything is possible."

[vanHorck]

Continued VFR on top in France.....

:ok:

[FREDAcheck]

"With EASA, anything is possible."
How about common sense? Or things that make aviation better, not just more restricted and expensive?

[flybymike]

Do the grandfathering proposals allow for continued lifetime privileges of those who have either deliberately or accidentally let their IMC ratings lapse? (subject of course to them being renewed by test as at present) or must the rating be kept valid continuously from inception until death?
I have a lapsed IMCR. Am I a grandfather?

[Pace]

I do not see this as good news at all. Firstly what about new pilots after those dates? Under these proposals there will no longer be an IMCR.
All EASA have said is that they have NO intentions of a European IMCR. The IMCR as a live rating will be dead as it will no longer ne in existance.
Those who have held one can carry on with its privalages as EASA will close a blind eye to what goes on over the UK.
That move is indicative that they have NO plans for a future EIR otherwise they would have said wait till our EIR comes out as it wont be far removed from your IMCR.
I do not see this as any sort of victory but a worrying indication that EASA have no intentions for an achievable IR or IMCR in their plans.

Have EASA said we are creating a European IMCR? NO
Have EASA said that the IMCR will continue in the UK? NO Only for existing pilots.
Have EASA said dont bother as we have an achievable IR in the works? NO
Bad news all round

Exterminate Aviation Strangle Aviators

Pace

[flybymike]

I must admit that I am just as cynical about the "concession" as Pace is.

[172driver]

Unfortunately, have to agree with PACE here. Throw a little bone to the Brits and let 'em chew on it. In the wider context of GA in the EU, the UK IMCr is totally irrelevant.

[Pace]

GA in the EU, the UK IMCr is totally irrelevant.

You said it in one. After X date the IMCR no longer exists. A new pilot turning up at the flying club wanting to increase his capability and safety by adding an IMCR will find no rating to do.

The flying clubs will have no IMCR rating to sell and hence there will be even less revenue to those clubs.

There is a solution and that is that the CAA make it clear we are having one regardless and will continue to support the IMCR in the UK as well as issuing ratings.

The French are the first to ignore regulations they dont approve of and shout until they are heard and I commend them for that why are we in the uk so compliant to everything that comes out of Brussels.

We have a different currency shame we dont become a 3rd country too :E and go back to the good old CAA

Pace

[IO540]

The IMCR was never relevant to Europe, because its IFR privileges have always limited to UK airspace.

Its possession allowed UK issued PPLs to fly VFR without sight of surface (above an overcast e.g.) worldwide, but most (all?) European PPLs can do that anyway.

The issue with the IMCR has been that EASA had taken the position that Europe must be standardised.

This is just circular-definition bollox. It's like me saying to a 5 year old he can't have the ice cream because I say so and I am bigger than he is.

Once you accept deviations in local airspace, and there is absolutely no rational argument against doing that, the whole issue goes away.

[Pace]

Once you accept deviations in local airspace, and there is absolutely no rational argument against doing that, the whole issue goes away.

Accepting deviation in local airspace is the problem as for as you say the IMCR has only ever been valid in the UK.

If deviation in local airspace was accepted then there would be no talk of the IMCR being abolished after X date with existing IMCR holders allowed to continue.


At the base of all this was the fact that the IMCR has been proved to be a safety rating for VFR pilots and there was a desire to extend its privalages and safety benefits into Europe as well as some of its IFR privalages OCAS.

That was turned down by EASA with vague hints at a more achievable IR instead.

For me the fact that EASA has held to its guns on ABOLISHING the IMCR so that it is effectively dead for future or new pilots is more worrying.

Had they any intentions of creating a significantly more achievable PPL IR for Europe they would have let the IMCR run till that came out.

All that has happened is that they have ABOLISHED the IMCR and thrown a few crumbs to existing holders to continue within UK airspace.

Reality dictates that EASA have killed the IMCR through the back door.

Pace

[englishal]

This is very good news (the grandfathering of the IMCr). IF the new EIR comes in, I suspect that IMCr or FAA IR holders will get credit towards it and this really means that a once IMCr *only* holder can now fly full blown IFR around the UK and *back* from Europe. The grandfathering of the IMCr allows IMCr holders to fly IAPs in Class D and below, and the EIR will allow "access to all classes of airspace" i.e. airways IFR. For the private pilot, this seems like a very good situation.

I have just renewed mine through an FAA IPC as I could see something like this on the cards, which means come 07/2012 I'll be an IMCr holder. I'd recommend that anyone thinking of doing an IMCr do so asap....

[IO540]

Why do you think you needed to renew yours? An IMCR never expires. You just need the 25m test flight, or a renewal based on an ICAO IR (+IPC if FAA), to exercise its privileges.

I wonder if this was clarified at the said meeting?

I agree that IMCR+EIR would be pretty good, if flying into southern Europe in the summer.

[englishal]

I suppose in case the wording is something along the lines of a "valid current IMC rating" when the fat lady sings....

[BEagle]

Look, the agreement in principal for grandfathering has only just been confirmed, so you can't expect every last comma and detail to have been thrashed out yet....

No, an ICAO IR is not sufficient for an IMCR. Nowadays it must be an IR on SPAs, not a multi-pilot IR. Specific details are in LASORS.

IMCRs become invalid after 25 months if not revalidated. Renewal criteria are described in LASORS.

FCL.008 has failed in several areas. It has neither provided the solution promised by Sivel at the CAA/EASA meeting in Kingsway, neither does it meet the assurance which Goudou gave to the European Parliament. You can expect AOPA to work on both these points during the NPA production period, of that you may rest assured.

[Genghis the Engineer]

Well it's certainly a step in the right direction; I'm glad but unsurprised to see that Cliff Whittaker was along for CAA - I've had a lot of dealings with him over the years and he has been unwaveringly pragmatic, supportive and sensible in his dealings with all light aviation issues, without ever once doing anything that caused significant problems later for CAA either.

I'm going to make educated guess here as to how it'll work out:

(1) Grandfather rights for existing UK IMC holders from 2012.

(2) Creation of a simplified SEP IR under EASA from about 2013, which looks just different enough from IMC that face is saved in Brussels.

(3) Some deal to allow UK IMC holders transfer to SEP IR privileges will start to appear about 2014.

(4) From around 2016 the UK IMC will slowly disappear into the history books as the EASA SEP IR starts to become workable across Europe and

Well, we'll see anyhow.

G

[IO540]

I reckon the above is about right :)

[Pace]

1) Grandfather rights for existing UK IMC holders from 2012.

(2) Creation of a simplified SEP IR under EASA from about 2013, which looks just different enough from IMC that face is saved in Brussels.

(3) Some deal to allow UK IMC holders transfer to SEP IR privileges will start to appear about 2014.

(4) From around 2016 the UK IMC will slowly disappear into the history books as the EASA SEP IR starts to become workable across Europe and

Genghis

I very much hope you are right as the ideal would have been an FAA style lower airways IR for Europe.

I have a number of issues and concerns.

The IMCR will not be retained in EASA eyes 2012 its gone.

Ok they say those who had it can carry on but the rating is effectively dead as no new pilots can get an IMCR.

My problem with this is partly a grave mistrust of EASA and its intentions! (smiles tea and biscuits and reassuring burps which are just the hot air )

But why get rid of or do anything at all regarding the IMCR if EASA have any serious intentions of offering a PPL IR?

Surley if they were serious EASA would have kept the status quo until the PPL IR was in shape.
They then would have offered allowances for UK IMCR pilots to convert to the PPL IR after that the IMCR would dwindle away.

It all very well Grandfather righting but you cannot grandfather right back to a Euro PPL IR from a rating which no longer exists in EASA eyes.

When we discussed all this a year ago I expressed my concerns about the IMCR being used as a Red Herring to divert attention away from a Euro PPL IR.
That was the goal we should have gone for.

All we have achieved is giving EASA a way out of both ratings.

I would be very surprised if a new PPL IR which is much different to an existing IR ever comes out of EASA. They may trim a scrap give it a name but in reality nothing will change for the better.

I see nothing in this allowance regarding the IMCR to applaud or cheer its a dead duck with an ominous smell. I await to be proved wrong and would rejoice if I am.

I really hope you are right

Pace

[dublinpilot]

I wish I could share Genghis optmism. What he describes sounds like a dream outcome.

If all that happens is grandfathering rights, then the IMCR will die off very quickly. With fewer people training for the IMCR, we will see fewer and fewer aircraft maintained to IFR standards. It's hard to justify a large repair expense, if a smaller and smaller percentage of your group members are instrument capable.

With fewer aircraft instrument capable, fewer people will revalidate their IMCR...a viscious circle.

Soon you will find yourselves in the same position as the rest of Europe... I would like to get an IR, but there are very very few aircraft available for private hire, or groups, which are legal for IFR flight, and even fewer that are well equipped.

[Justiciar]

I am puzzled by what all this means. On the face of it it seems to be a much better result than could have been hoped for and I hope it means what it says.

The IMCR does not fit anywhere into the current proposed Part FCL. It is not a rating issued under JAR nor is it a rating associated with the NPPL and even if it were there is no comparable EASA rating and the regulations assume that national ratings are mirrored by similar EASA ratings.

So, we now seem to have a concesssion which is wholy contradictory of the whole EASA/Part FCL regulations ethos. I do not see how the IMCR can be grandfathered under the current Part FCL proposal and they would have to be amended to allow this to happen, as rules would in effect be needed to enable NAAs to grant their own national ratings. This would have to be sufficiently generic to be applied EU wide, as I doubt that singling out the UK for special treatment would be considered acceptable.

I do wonder whether this concession is the start of a face saving exercise which will see the Part FCL draft withrawn for a rewrite. May they even be anticipating being sent away by the Commission to try again? What ever we think of the parentage of some members of EASA they and the Commission cannot be deaf to the rising clamour of protest, especially now from the US at the impact of the proposals on the US economy. When phrases such as “a smokescreen for political chauvinism.” and "potential regulatory and trade consequences" start to be used by the US the euorocrats and politicians are going to start to take notice. The last thing anyone will want in the midst of a global recession will be the erection of trade barriers between Europe and the US.

[IO540]

Indeed, especially with the EU being close to a political meltdown (with Germany having just bought Greece to keep it together for a bit longer, etc).

EASA is carrying on like nothing was happening.

Dublinpilot makes a very good point regarding the demise of IFR capability among aircraft other than those owned by sole IR-rated owners or the few all-IR syndicates. This is bad news**, which will incidentally also undermine the demand for GPS approaches (which are themselves struggling to be relevant to GA because most places whey they are really needed there is no ATC, but ATC is mandatory for any instrument approach).

** Somebody will be around any moment saying that IFR GA is irrelevant and that GA can move en masse to farm strips. I don't think so....

[Justiciar]

There is an irony in the EU advocating the harmonisation of licensing rules across Europe as being a good thing and at the same time erecting a barrier to the movement of pilots across frontiers from outside the EU whilst adopting a stance which treats third country licences as so inferior that they are not worthy of being easily converted to an EASA licence.

These positions are mutually inconsistent and smack of the worst sort of protectionism. I suspect that many more people will in due course protest as the damaging consequences of these proposals become clearer and as it becomes apparent that many more current commercial and other operations are affected in a way which has neither been forseen or intended. Although this debate has to a large extent be conducted in terms of "N" registered pilots and aircraft I am sure that many other non EU countries will be affected by these regulations. The effect on non EU European countries such as Switzerland, Iceland, Norway, for example, is not clear.

[old-timer]

apologies if I've missed this along the way but will it only apply if the IMC is still currrent; i.e can a lapsed IMC be re-instated ok or should it be renewed asap (obvious answer I know is to renew asap in any case but just wondered if EASA rule will covers both lapsed & current IMC's)

many mysteries abound the land of the easa bird :ooh:
does sound promising though, common sense may even prevail in the end :D

[Pace]

Old Timer

These proposals are not due until 2012 if ever as nothing is set in concrete YET! there would be no point in renewing your IMCR unless you need to yet.
I would renew nearer that date so that it is current if EASA hasnt been booted to where it deserves to be booted before then! just as a precaution as God knows what they will do.

Pace

[englishal]

If you renew it now, it will be valid in 07/2012 which is the date the fat lady sings...

[old-timer]

Ahh - I see the EASA logic now, 2012 coincides with the end of the mayan calender & 'alleged' end of everything :uhoh:

the easa bird is a very strange bird indeed, perhaps it might even become extinct ! (very unlikley) - I vote to bring back common sense......but common sense has gone out of the window forever I fear these days. :{