EASA AND THE IMCR - NEWS [Archive] - Page 2

dublinpilot

2nd Oct 2011, 10:39

dublinpilot, if you take a look at the NPA, you'll find a good description of the destination and alternate aerodrome forecast requirements for the EIR. There are also much clearer statements concerning acceptance of IFR clearances than hitherto.

Ok, then I have misread your initial post. I thought some change had been agreed at the workshop, but now understand that no change has been made.

How are you going to make sure you are going to be VFR at the enroute sector terminating waypoint, say FL100, and with say 30nm to run to the airport for which you can get tafs and metars (and anyway cloud above 5000ft/MSA is not reported)?

IO,

This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.

As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.

It's obvious to me that in all likelyhood using the EIR will require better weather conditions that VFR flight would. If you can't be sure of completing it under VFR, then you can't be sure of breaking out above 1000ft above any obstacles within 5nm.

It will of course allow you to build instrument time towards a full IR by flying under IFR when you would otherwise still have made the trip but under VFR, and it will allow you to fly on top of some local low cloud, but I don't really see it as providing a great deal towards safety, other than allowing an easier staged progression towards the full IR.

dp

Pace

2nd Oct 2011, 12:22

Prob the usual EASA tea and biscuits Meeting with emty promises ?

Pace

BEagle

2nd Oct 2011, 12:32

Ok, then I have misread your initial post. I thought some change had been agreed at the workshop, but now understand that no change has been made.

No, this was a workshop. The normal NPA/CRT/CRD/CRD response/Draft Opinion process will now follow. We highlighted a few points and made a few suggestions for the way things could go, but the statutory process is the next stage.

IO,

This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.

As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.

The transition procedure from IFR to VFR will be more exercising than simply flying IFR all the way to the FAF. EIR pilots will need to have good radio standards and to have good back-up plans for their intended flight; they will also need to be quite sure of what the rating will or will not facilitate. So the trip profile might not be as efficient as ideal, but it should at least be possible. If the descent and transition proves to be too difficult for some aerodromes, then this will probably act as a spur to upgrade from EIR to the 'new' IR!

Prob the usual EASA tea and biscuits Meeting with emty promises ?

No, it was a very useful and equable workshop. And there weren't any biscuits!

The "demonstrate knowledge" should be an oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs.

Might I suggest you make that point in your NPA response? Others at the meeting made similar comments, as will I when I submit my personal NPA response.

If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question.

Quite so. But to be taken seriously, please remember to:

1. State the reference upon which you wish to comment
2. State your counter proposal
3. State the justification for your counter proposal

Jim has already done a good job of de-bolleaux-ing the LOs, but any further constructive suggestions will of course be followed up.

IO540

2nd Oct 2011, 14:21

It's obvious to me that in all likelyhood using the EIR will require better weather conditions that VFR flight would. If you can't be sure of completing it under VFR, then you can't be sure of breaking out above 1000ft above any obstacles within 5nm.I don't see it quite that way.

If I look at any of my long VFR (pre-IR) trips, which were up to maybe 800nm in one leg, all of them involved flying above (often high above) some low cloud. In N Europe, it is pretty normal to have cloud between say 2000ft and 5000ft.

UK PPLs fly almost totally below such cloud, and cannot go above it even if one can find the proverbial hole because of Class A.

With the EIR, you will be able to cross this stuff, high above it, on an IFR clearance.

It is very hard (if not impossible, though I have never tried it) to fly hundreds of miles under whatever cloud one encounters. Actually I did try it once, coming back from Biarritz, in 2003, and busted one of the French power station TRAs as a result (they were not shown on the charts back then, or in notams) :)

But as I said I am pretty concerned about the STAR ban, because there is no easy (and certainly no "official" i.e. might be trained at an ATO) way of checking the wx at some point 30nm before the destination, at FL100-180.

The SID ban would, if nothing else, be a huge irritation to ATC at airports, because the pilot would have to depart VFR, and mess around, looking for a hole in the cloud (which is possible only OCAS) and then rejoin CAS to join up the start of the filed route.

1. State the reference upon which you wish to comment
2. State your counter proposal
3. State the justification for your counter proposal Not sure how to do that. Bollox is self evidently bollox. How do I dig out a reference for it being bollox?

If they stripped out TK items which are not bollox, they would not be left with much. BUT it's hard to say how much, because the FCL008 document lists learning objectives (i.e. the TK syllabus) and not the questions which will appear in the multiple choice exams. You could have reasonable LOs (e.g. "state the conditions for airframe icing") and then some idiot drafting the QB might generate loads of utter bollox questions based on that. My generous estimate of non-bollox in the current JAA IR TK is under 10%, but obviously that is the QB, not the LOs. I haven't got a clue what the LOs are, and most of them probably don't sound all that unreasonable.

The only thing which has kept a lid on the bollox in the QB has been the UK CAA weeding out the worst ones. As a result I saw very few in the actual IR exams I sat. But the EIR/FCL008-IR is meant to be pan-EU and a pilot sitting this in say France is likely to get the whole lot.

It is a direct consequence of nearly everybody involved in the TK not having ever been a pilot.

Not a lot one can do about that, except maybe draw attention to it.

dublinpilot

2nd Oct 2011, 14:47

In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC.

I find this rater interesting on two counts.

Firstly my reading says to me that an EIR holder can plan to an airport with marginal conditions and see what it's like when they get there, if they have an alternate which is in forecast VMC +/-1 hour.

Secondly it calls for the airport to be in VMC. I take this to mean that it's capable of accepting landing/departing traffic under VFR. It's quite possible to have an airport in VMC, but which still have an OVC which is below 1000ft above the highest obstacle within 5nm. It seems to me that if an EIR holder was stupid enough to try it, they could plan to an airport that they had no chance of landing at.

Should they not have said that the destination should have forecast conditions which would allow the flight to arrive under VFR rather than state that the airport itself if VMC?

IO540

2nd Oct 2011, 14:54

Obviously, yes.

"VMC" is meaningless. Most airports in CAS will have VFR minima c. 1200-1500ft cloudbase. Any lower, and you are grounded if already there, and you cannot arrive VFR except as a mayday.

BEagle

2nd Oct 2011, 15:05

Bollox is self evidently bollox. How do I dig out a reference for it being bollox?

Perhaps by stating that the item of bolleaux is not an FAA requirement for the IR (you would need to quote the specific AIM ref.), so there is no logical justification for it to be included in any EASA version?

Firstly my reading says to me that an EIR holder can plan to an airport with marginal conditions and see what it's like when they get there, if they have an alternate which is in forecast VMC +/-1 hour.

No. Both the destination and alternate aerodromes must meet ICAO VFR criteria for ± 1 hr of planned ETA. So at an airport with a Class D CTR, you would need 5km vis and to remain 1000ft vertically and 1500m horizontally clear of cloud, but at Little Piddle on the Gusset aerodrome in Class G airspace, perhaps without even an ATZ, at or below 140KIAS and 3000ft amsl you would need to be clear of cloud and in sight of the surface with only 1500m in-flight visibility.

SVFR adds further confusion as it has different meanings in different nations. So perhaps best just to leave it out of EIR discussions?

dublinpilot

2nd Oct 2011, 16:24

No. Both the destination and alternate aerodromes must meet ICAO VFR criteria for ± 1 hr of planned ETA

I don't think it says that BEagle.

You say destination and alternate aerodromes

The NPA says destination or alternate aerodrome

Thinking about it, it presumably is worded like this to allow a pilot to plan to an airport where the forecast is generally good, but it does have a tempo or prob 30 in it for sub VFR conditions, provided that their alternate doesn't have such issues.

dp

BEagle

2nd Oct 2011, 17:24

dublinpilot, yes, you are correct - that's how the proposal has been written.

However, I think that it's tempting fate to allow EIR holders to have a sniff, then divert. The ± 1 hr should take care of any TEMPO because TEMPO is used to indicate a period of temporary fluctuations to the forecast conditions during a specified part of the TAF. The fluctuations are expected to last less than one hour in each instance and in aggregate less than half the specified period.

I vaguely remember that you aren't allowed to take off unless your planned destination is forecast to be within your limits at your planned ETA, but am open to correction!

Some years ago I was based at RAF Wattisham on the F-4. One day our SATCO told us that some light aircraft had asked to divert in as its destination was out of limits. He checked the pilot's destination forecast and it was obvious that there hadn't been a cat in hell's chance of it being in limits for most of the day, so the diversion was refused and the pilot was advised to call Norwich or Stansted....:\

My rule of thumb used to be to ignore TEMPOs unless both destination AND alternate were TEMPO'ing below limits.

bookworm

2nd Oct 2011, 17:33

That's correct DP. And there's a twist.

Under ICAO Annex 6, the requirement for an IFR flight is:

"2.2.3.4.2 A flight to be conducted in accordance with the instrument flight rules shall not be commenced unless information is available which indicates that conditions at the aerodrome of intended landing or, where a destination alternate is required, at least one destination alternate aerodrome will, at the estimated time of arrival, be at or above the aerodrome operating minima

2.2.4.1.1 A flight shall not be continued towards the aerodrome of intended landing, unless the latest available information indicates that at the expected time of arrival, a landing can be effected at that aerodrome or at least one destination alternate aerodrome, in compliance with the operating minima established in accordance with 2.2.2.2"

The logic is very clear. You need destination or alternate above minima, not both. For an IFR flight, this may be reasonable. However, at the very last minute of the preparation of the EASA Part OPS CRD, the wording was changed to:

"NCO.OP.145 Destination alternate aerodromes – aeroplanes
For IFR flights, the pilot-in-command shall specify at least one weather-permissible
destination alternate aerodrome in the flight plan, unless:
(a) the available current meteorological information indicates that, for the period from
1 hour before until 1 hour after the estimated time of arrival, or from the actual
time of departure to 1 hour after the estimated time of arrival, whichever is the
shorter period, the approach and landing may be made under visual meteorological
conditions (VMC);

Weather-permissible aerodrome’ means an adequate aerodrome where, for the
anticipated time of use, weather reports, or forecasts, or any combination thereof,
indicate that the weather conditions will be at or above the required aerodrome
operating minima, and the runway surface condition reports indicate that a safe
landing will be possible."

That changes the logic (for all non-commercial IFR flights) slightly, and even though I think you have to be a lunatic to take-off when your destination is in hard IMC and your alternate is below minima, I don't think the consequences of the change are intended.

Given the EIR is rather weather sensitive, I did make the suggestion before the FCL.008 NPA was published that for the EIR and was more appropriate than or, but it was too far down the road to publication. It would be a very fitting topic for a comment.

bookworm

2nd Oct 2011, 17:41

My rule of thumb used to be to ignore TEMPOs unless both destination AND alternate were TEMPO'ing below limits.

For what it's worth, there's a new AMC proposed in Part-NCO (non-commercial OPS) for interpreting TAFs for the purposes of aerodrome operating minima.
AMC1-NCO.OP.165 Meteorological conditions

It echoes the way that JAR-OPS1 used to do it. Essentially (and please, read the AMC before relying on these rules of thumb):

* During a BECMG period, you take the worst weather
* You can disregard any PROB30 TEMPO
* You can disregard a TEMPO related to transient/showery conditions
* You must take account of a TEMPO related to persistent conditions like fog
* You should always disregard a TEMPO improvement

dublinpilot

2nd Oct 2011, 18:08

Given the EIR is rather weather sensitive, I did make the suggestion before the FCL.008 NPA was published that for the EIR and was more appropriate than or, but it was too far down the road to publication. It would be a very fitting topic for a comment.

While I understand why changing it to "And" would make it safer, it would make finding such weather conditions quite difficult! Tempo and Prob30's are so common even on pretty find days, that not being able to ignore them at one airport (which the "or" allows you to do) would make the EIR quite restrictive.

BEagle

2nd Oct 2011, 19:55

bookworm, I should have perhaps added that my 'rule of thumb' was for the operation of military aircraft (VC10) where no specific interpretation of TEMPO at both destination and alternate was mandated. In fact I used more or less the rules you quote!

I agree that 'and' would be more appropriate in the EIR context.

Pace

2nd Oct 2011, 20:21

Beagle

If their offering tea but not biscuits maybe EASA have had a cut in their massive budget:E

Seriously as 10540 said its a load of bollox. Weather at destination or what its forecast or not forecast has very little relevance to you trying to safely change from IFR to VFR IMC to VMC 50 miles away!

What procedure are EASA suggesting that the pilot leaving his last waypoint to become VFR for a VFR approach follows If on reaching his MSA he is still in solid cloud and in IMC? Does he take a direct line to a destination at MSA busting airspace in the process? does he climb back to IFR levels to his diversion descent point again 50 miles out from there what is the procedure that EASA require?

Enroute the happy pilot is in the blue over nothern france he has a major problem but all the airfields below are giving an RVR of 700 metres with overcast at 300 feet.

Whats does EASA suggest the now unhappy pilot does?
I really feel some of these rule makers have no idea of the reality of flying and are totally naive.

Pace

dublinpilot

2nd Oct 2011, 21:05

dublinpilot, if you take a look at the NPA, you'll find a good description of the destination and alternate aerodrome forecast requirements for the EIR. There are also much clearer statements concerning acceptance of IFR clearances than hitherto.

I've now gone through the entire NPA, skipping stuff solely about the sailplane cloud rateing and skipping the LO's.

The only paragraph that I've come across about the above is the one that I quoted earlier...ie In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC.

Is that what you refer to when you said
Of note is that the previously perceived 'dangerous' elements of the EIR, namely the IFR-to-VFR transition and the rather imprecise 'reasonable expectation' of VMC at destination have now been addressed satisfactorily, although further refinement will follow the NPA response.

If it's something else you might do me the curtiousy of tell me what it is your refer to so I don't have to read it a second time and guess again ;)

Fuji Abound

2nd Oct 2011, 21:24

Pace

He would do the same as a pilot with an ir. The only real difference between the two is in their respective dh. I dont see why it is such a problem.

There is clearly much detail to resolve but in theory it is capable of working.

BEagle

2nd Oct 2011, 22:11

dublinpilot, yes, that's what I meant. The original draft proposal merely said something far less precise - 'reasonable assurance of VMC at destination' or somesuch.

What procedure are EASA suggesting that the pilot leaving his last waypoint to become VFR for a VFR approach follows If on reaching his MSA he is still in solid cloud and in IMC? Does he take a direct line to a destination at MSA busting airspace in the process? does he climb back to IFR levels to his diversion descent point again 50 miles out from there what is the procedure that EASA require?

I really do not understand what it is you're trying to say.

Pace

2nd Oct 2011, 23:36

BEagle

What I am trying to say is that Pilot A has to at some point enroute to his destination have to transit from IFR back to VFR.
He can only enter his destination airport under visual flight rules.
He cannot make that descent in cloud to become VMC under a safe predetermined safe route ie a STAR but has to make that descent not knowing at what altitude he will break out into VMC or if he breaks out what cloud or visibility will be below him!
he will not even know in his descent whether legal VFR conditions lie below him.
You are expecting him to transfer to VFR when he has no clue whether VFR conditions exist.
It is very clear! What are EASA telling such a pilot to do in such a circumstance or are they saying it is his problem?
They are saying he must have VFR conditions at his destination for an hour after his arrival time but that is weather at his destination not his descent point so almost irrelevant to him.
Ok this may only apply to busier airports as the obvious would be to fly from that point at MSA to the destination overhead where weather is accurate and spiral down for a visual circuit.
Are EASA saying he is banned from larger busier airports?
I cannot see what is not clear to you?
He is not making a home made approach into a UK VFR airport but into airspace he is not allowed to enter in cloud at any point and following VFR visual routes he may not see.

Pace

IO540

3rd Oct 2011, 07:03

He would do the same as a pilot with an ir. The only real difference between the two is in their respective dh. I dont see why it is such a problem.That would be true if it wasn't for the ban on STARs and SIDs, which requires the pilot to cancel IFR at the enroute section terminating waypoint.

Take this flight (http://www.peter2000.co.uk/aviation/kithira/egka-ljpz-big.jpg) for example (L to R). The pilot would have to cancel IFR at ILB, where the wx could be very different (at FL150) to the wx at LJPZ.

Re the SID ban, take this flight (http://www.peter2000.co.uk/aviation/kithira/lszr-egka-big.jpg) for example (R to L). He would have to proceed VFR all the way to TRA, 47nm away, and he will have to climb to the enroute altitude by then, say FL100, without entering IMC. This means the EIR will be suitable for departures only in totally blue sky conditions.

BEagle

3rd Oct 2011, 07:34

What's to stop you filing something like (EGKA - LJPZ) ......ILB DCT ILB250030 VFR DCT?

Or (LSZR - ?) DCT ZUE120020 IFR DCT TRA.......

(I'm guessing at the bearings in each case!)

Not quite as simple as typing wpt names into your nav system, but creating a personal VFR-to-IFR or IFR-to-VFR en-route waypoint by place/bearing/distance doesn't seem like rocket science to me, provided that you follow FPL conventions for the nations involved and that their airspace allows you to fly under VFR where you wish to?

Perhaps RMK/PILOT HOLDS EIR might also help - assuming that the ATS provider bothers to read the full FPL, of course!

Pace

3rd Oct 2011, 08:42

BEagle

As an outsider to the negotations if thats what they are called there appears to be a lot of naivety and sticking heads in the sand with the proposals for the EIR.
On the face of it all the EIR seems to offer the VFR pilot the ability to go high, simplify his trip by not needing to circumnavigate chunks of airspace.
The pilot gets better radio reception simplified radio and better nav reception.
But there appear to be potential pitfalls where there is a lot of sticking heads into the sand and why?
Because we cannot have anything which can be seen as a mini IR which competes or treads on the feet of its bigger brother.
Again EASA not facing up to their mandate of safety.

Pace

IO540

3rd Oct 2011, 08:58

BEagle

I have never tried that hack. I have simply always done "IFR" in the "classical" manner i.e. develop a Eurocontrol route (using Flightplanpro, etc) and this gives you the terminating waypoints directly, which join onto the sids/stars published for that airport (Eurocontrol have all sids and stars in their database). That is how one is supposed to do it and it is what ATC expect.

Your method has been used, as an enroute hack to circumvent Eurocontrol route validation. It is possible to get a flight plan into the system on any route whatsoever if one specifies each waypoint as VORrrrddd because this disables Eurocontrol route validation (well, maybe not if the leg thus specified crosses a national frontier, or exceeds the DCT MAX for that airspace) but I don't think ATC like it very much if the result is something really nonstandard.

I have enquired about this in the past on ATC forums and it appears that the ability of the ATCO to see a thus specified route graphically (i.e. make sense of it) varies from one country to another.

Also, if you fly non-validated routes, you do need to get enroute notams, because the filed route won't be protected from military etc exercises by the normal mechanism of Eurocontrol (IFPS) checking, and when you actually fly it, ATC are going to divert you somewhere else.

But the biggest issue I suspect is that you are filing a nonstandard procedure which will play havoc with ATC expectations in the terminal area.

On the flight to LJPZ (which I did the other week) what actually happens is that you can get, by asking, a DCT to LJPZ as soon as you are in Slovenian airspace (at PESUT) and at that point you get a stepped descent, which in the GA context can usually be implemented as a continuous descent. So this is perhaps a bad example, since that part of the world is really relaxed.

Switzerland (LGKR-LSZR (http://www.peter2000.co.uk/aviation/kithira/lgkr-lszr-big.jpg)) would be more prescriptive. They definitely want you at or around KPT, and from there you get vectors to the ILS.

Perhaps RMK/PILOT HOLDS EIR might also help - assuming that the ATS provider bothers to read the full FPL, of course!

I think you are assuming a whole new dimension in ATC training. Maybe it will happen...

Re reading the full FPL, ATC don't see the full FPL. IFR controllers normally see just the filed route, I gather. The full FPL is retrieved only if you go missing, etc.

rdbc2007

3rd Oct 2011, 16:55

Can anyone answer whether or not it is worth completing an IMC course considering the latest update from EASA.

I'm a couple of hours into mine so contemplating if it's worth proceeding.

Cheers:bored:

Timothy

3rd Oct 2011, 18:29

Definitely. It will give you approach rights in the UK forever.

liam548

3rd Oct 2011, 20:02

im about 10 hours into mine and have the theory in the bag too. I am hoping it will still be valid in 12 months time however The PPL IR site states,

"
It seems that the CAA is making a case to keep the rating but the runes are against them.
PPL/IR will continue to make suggestions and to lobby, but IMCR holders and training organisations must brace for the possibility that the hard won privilege will disappear within the next couple of years."

BillieBob

3rd Oct 2011, 20:12

I wouldn't take to much notice of what appears on the PPL/IR site regarding the IMC Rating. There are multiple vested interests at work in that organisation, which has been anti the IMCr from the start. I wouldn't be at all surprised if the future of the IMCr was to turn out to be more secure than that of EASA, or even the EU.

liam548

3rd Oct 2011, 20:45

Actually i believe the quote i used is an old one and the up to date response to the latest developments are here.

PPL/IR Europe - Qualifications for Flying in IMC: NPA Published (http://www.pplir.org/index.php?option=com_content&task=view&id=571)

Timothy

3rd Oct 2011, 21:01

I am the Editor of the PPL/IR website, and have been remiss if that is in the editorial.

Remember that the website has a lot of aged opinion pieces. I don't know where that quote comes from, but it definitely predates the NPA.

I will be putting more recent copy up when the dust settles. At the moment opinions are developing by the hour.

And BillieBob is simply wrong about the attitude of PPL/IR towards the IMCR. He or she may have spoken to a member or two who are opposed. We don't screen members for their opinions!

liam548

3rd Oct 2011, 21:09

IO540

3rd Oct 2011, 21:11

There is nothing concrete about the IMCR anywhere, currently.

But its demise is very unlikely.

If you go back a few years, EASA's position was total absolute standardisation across the EU (unless it was France in which case they could keep all their stuff ;) ).

In very recent months, they have abandoned that position.

It could be political reality, driven by the current near meltdown of the EU. Obviously that doesn't help EASA, which needs the EU to pass the laws, but I wouldn't over-estimate it. EASA, as an employment agency, will run at maximum speed until it hits the rocks. There is no other option. Turkeys will never vote for xmas.

I think that more likely they have spent a lot of political capital (meaning: under the table assurances given to Euro MPs, as covert inducements for supporting EASA proposals) on what they have dragged out so far, and they cannot pull off another "Poll Tax sized" project cleanly. The only way forward is to compromise here and there.

The French national IR has been another factor. Ostensibly it cannot exist past April 2012, or April 2014, or whatever, but everybody knows that the French will just run with it, and stick a finger up to EASA/EU. This snub of EU authority would have hit EASA hard because they know that the UK could do the same if it wanted to, and the EU could do absolutely zero, zilch, nowt about it.

If you want any more, get yourself the complete set of Yes Minister DVDs, watch it, and come back if you have any questions :)

EASA is politics, not aviation.

Timothy

3rd Oct 2011, 21:15

Thank you. I AM ON THE TRAIN, but will look when I get home...

...now edited to make it clear that that opinion was expressed four years ago.

BEagle

4th Oct 2011, 19:07

that opinion was expressed four years ago.

Quite a lot has happened in the last four days, let alone months or even years, to modify / overturn earlier held opinions!

So keep 'em peeled for emerging news. In a nutshell, IMCR, EIR and 'new' IR all have their place; the problem will be to find an equable solution to the UK IMCR situation which will allow EASA to concede their earlier held position.

We think we may have a way. Certainly Europe Air Sports and IAOPA think so!

(Timothy, I hope you remembered your Ian Allan trainspotter's guide...;) )

awqward

4th Oct 2011, 21:51

Is there anyone who has had experience of the Australian PIFR (Private IFR) rating. It involves an enroute only rating with optional add-on approach and departure competencies...I guess most would get the GPS approach competency...but I don't know...any comments from Australia?

IO540

4th Oct 2011, 21:59

The PIFR is well known to EASA committee members.

I don't know why the principle was rejected. Perhaps because flying just one type of approach is not very useful, especially if alternated need to be considered. Another factor is that there is a resistance (probably correctly) to producing a "second class IR" because that could lead to lobbying (by airline and ATC unions, probably) to block such pilots from certain airports and certain airspace classes - a thin end of a wedge.

So, the end proposal was for the EIR whose termination is clearly VFR-only, and the FCL008 IR which is fully ICAO compliant.

Like America, Australia can do a lot of good sub-ICAO stuff because almost none of their private pilots ever leaves their airspace. Like automatic acceptance of FAA STCs; EASA would do that over its dead body.

Fuji Abound

4th Oct 2011, 22:21

Io - i agree with everything in your last post except the last line.

I guess it is true that europe is unable to disassociate itself from the plethora of each individual states interest and in that much i agree with you but whilst our discussion is that of idealists it is at the heart of europe and easa to behave as if we were one nation in exactly the same way as australia or america and in that much easa has the same opportunity - sadly an opportunity they have chosen not to take.

It is a significant point because if you are correct it would suggest easa has failed at the most fundamental level - namely to set aside national interests.

However i dont think easa is guilty of the crime you suggest - i think it is much simpler - they dont want to be seen tainted with the american brush, they dont want to bow to americas perceived dominance in aviation, and so far as australia is concerned they dont want to be seen to be copying some one elses model.

In short we are going to do things our way and we are not getting into bed with the yanks.

awqward

4th Oct 2011, 22:27

The PIFR standards are the same as the full IR...(same tolerances on the flight test etc)...so it looks equivalent to the EIR...I don't know how many Australian pilots only have the enroute rating without any approach approvals but it would be interesting to hear how they get on....

I suspect most would at least get the ILS/LOC/DME and GPS arrival approvals as even dirt strips in the bush often have a published GPS procedure...so maybe there are very few with just the enroute rating...of course the traffic and radar situation is very different there...

Ellemeet

4th Oct 2011, 22:54

Interesting to see how everybody has a strong opinion on this subject.

Is there going to be a good transition for IMCr to EIR? if so, what is the problem. Then the UK IMCr pilots can use their skills in the same way abroad?

I am more interested to see what the next steps are... Will Europe finally start coming with GPS approaches, especially on a lot of smaller airfields? And will we be getting rid of the NDB approaches?

Can we finally get some proper weather services like the US have NEXRAD and can we have TIS???

Also... if I get my PPL/IR ... and want to upgrade to CPL/Ir or (frozen)ATP(IR) ... can we get rid of some of the 14 theory exams....

Lets please make things sensible!!

awqward

4th Oct 2011, 23:00

Fair point Silvaire1....The US has twice as many pilots, 5 times as many with IRs, very high mountains, deserts, very high density altitudes, extremely dense traffic, sparse traffic, tropical, temperate, intense frontal systems, hurricanes....a superior safety record...superior system including XM data & weather, WAAS based LPVs....but apprently inferior training and an inferior instrument rating...? ;)

IO540

5th Oct 2011, 06:44

Fuji - I think you are right on both counts i.e. EASA has failed to remove national interests (obviously, because the national CAAs, etc, lobby like hell against stuff which would cause job losses) and they also don't like the USA so a lot of stuff, if it so happens that it would be similar to the way the USA does it, has to be dressed up with different names, small changes, gold plating, etc.

Ellemeet - All this FCL008 IR stuff is for private pilots only. I don't see any effort going on to reduce the 14 CPL/IR exams which are so full of bollox and which are nowadays a charade because the whole FTO sausage machine swats them up using the question bank.

BEagle

5th Oct 2011, 06:46

NPA 2011-16 will allow IMCr time to be credited, it would certainly seem.

The PIFR includes an ability to add up to 24 different 'Flight Procedure Approvals', which makes administration something of a burden. EIR and 'new'IR are much simpler; however, we still need a solution for wholly national needs for some Member States.

The 'new'IR will include FAR less theoretical knowledge than its predecessor; moreover, instrument flight time achieved elsewhere (e.g. EIR holder gaining IF experience) will be creditable.

The proposals of NPA 2011-61 make a lot of sense; however, comments made using the EASA Comment Response Tool are vital in order to create a Comment Response Document as soon as can be achieved; this can then be taken forward.

flybymike

5th Oct 2011, 11:44

Where can I enrol on a course to learn how to use the EASA comment response tool?

BEagle

5th Oct 2011, 14:37

flybymike, try EASA CRT application (http://hub.easa.europa.eu/crt/)

FREDAcheck

5th Oct 2011, 15:05

...EASA would do that over its dead body.
I don't see that as a problem:)

Fuji Abound

5th Oct 2011, 21:42

The CRT is a web-based application. It has been successfully tested and is supported on Internet Explorer 6+ (SP2 must be installed), Firefox 2.x & 3.x.
It has been successfully tested on Opera 9.x, Safari 3.x and Google Chrome, but those browsers cannot be considered as supported.
CRT does work without know issues with MS Office 2003 up to SP 3, but later versions cannot be guaranteed, nor any other office tools.
Documents in the CRT will be provided in two formats; Acrobat (.pdf) and FlashPaper (.swf). The required programs, Adobe Reader and Adobe FlashPlayer, are available for free download, see links below.

So does that mean easa are using non euro approved software - american to boot? Shirley they should develop and implement brussels 1.x.

swflyer

4th Nov 2011, 17:06

Sorry if this has already been asked.

I know that as a colour blind person I can get a UK IMC but would the European IR end all that? Does anyone know? Would you have to have perfect colour vision for that?

In short, is this the last chance to get something that allows me to fly in cloud ever? Would grandfather rights survive?

Any ideas?

Ps. I've failed all the tests, lantern, holmes, you name it.

IO540

6th Nov 2011, 08:47

The medical requirements for the "CBM IR" (as it is now called, apparently - competence based modular) seem to be the same as the ones for the JAA IR.

I have heard that some pilots have got the JAA IR in the UK with a day-only restriction. It seems very rare. But then the day-only IMCR was totally unheard of - until some people revealed the CAA had been doing it for years, quietly.

There are some possibly helpful medical concessions around in the UK - here
(http://www.caa.co.uk/docs/49/20100624UKCAADeviationPolicy.pdf)
The IMCR looks like it will continue.

Timothy

6th Nov 2011, 11:03

The IMCR looks like it will continue.
That's a bold statement!

There are three versions of what "continue" might mean.

Grandfathered rights for existing holders - this seems to be assured
Ongoing ability to get a new rating on non EASA aircraft like the Chipmunk - this seems likely, but I don't think assured (I may be wrong)
Ongoing ability to get a new rating on EASA aircraft - we will fight for this, but the outcome is very far from assured.

The Grim EPR

6th Nov 2011, 11:24

swflyer - Have you tried the relatively new CAD test at the CAA in Gatwick?

CAA research paves the way for more people with colour vision deficiency to become pilots | CAA Newsroom | CAA (http://www.caa.co.uk/application.aspx?catid=14&pagetype=65&appid=7&newstype=n&mode=detail&nid=1756)

It may be an option open to you. People have failed the plates and lanterns, but have passed this. Once passed, you don't have to repeat the test and have a full Class One medical colour vision sign off.

IO540

6th Nov 2011, 17:23

Grandfathered rights for existing holders - this seems to be assured

The usefullness of this depends on when the deadline for new IMCRs will be. It might be April 2012, or a bit later.

Currently very few people are doing the IMCR - about 250/year, down from 3x that much some years ago.

No doubt the decline is partly because it has been slagged off for so long by so many people, including some very high profile forum personalities who post on various forums saying how useless IMCR pilots are compared to IR pilots...

In reality it is a debate concerning a comparison between renters and owners, basically, where one would expect big currency-on-type differences between the two pilot populations. Most good IMCR pilots are owners, and most IR holders who just occassionally rent are crap IFR pilots.

Timothy

6th Nov 2011, 17:40

I see three types of IMCR pilot:

Those who treat the IMCR pretty much as an IR, stay in currency and are very good.
Those who do a bit from time to time and are not very good.
Those who only fly IFR every 25 months for renewal and keep the IMCR in the bottom drawer, just in case. They are generally awful.

I suspect that there is indeed a correlation between those characteristics and ownership, but it is a very long way from 1:1. Most people I mentor are partial owners, and they fall into all three categories, but I can think of at least two in the first category who rent.

Genghis the Engineer

6th Nov 2011, 17:54

Timothy

6th Nov 2011, 18:10

The same is probably true of IR holders who don't work in a job which requires it regularly.
Maybe, but that is not my experience.

I fly a great deal with people with PPL/IRs (both FAA and JAA/CAA), none of whom are professional line flyers (some have ATPs and CPLs, but they don't use them) and I have only seen a high level of capability and professionalism.

That is not to say that that there are no gash PPL/IRs, far from it, but I have to say that the standard I see is very high.

I think that that is because most PPL/IRs make almost every flight under IFR, right through to an IAP, even when VMC, whereas most IMCR holders don't.

IO540

6th Nov 2011, 18:39

My knowledge of this comes partly from being in contact with a very large number of pilots, and partly from having been renting out my plane some years ago and seeing the sort of people who turned up wanting to fly it.

Most IMCR holders are renters or, to a smaller degree, syndicate members, and most of the latter are having constant aggro with VFR-only members who are refusing to pay for keeping going what they regard as unnecessary avionics. I would say the vast majority of syndicates that have one or more IMCR members are continually on the verge of falling apart due to this.

This does not encourage IFR currency, because currency comes from frequent flying, which (in the long run) comes only from enjoyable flying, which in the long run rules out burger runs.

And renting has the highest marginal cost which maximally discourages currency.

I also found that almost every IR holder is already an owner. Very few exceptions. There are a very small number of IFR only syndicates, which tend to be very successful (not least because IR members will have deep pockets and tend to not bicker about trivia so much ;) ). The remaining IR holders were mostly fakes, or lapsed IRs (most of those were instructors, spinning some great yarns, and fiddling the fuel totaliser to get reduced fuel billing), and a really miniscule # of serving airline pilots who actually liked flying IFR "GA" as well as doing it at work in jets.

So it is no wonder that IR holders tend to be so much more current. An IR is worthless unless you go places, and you can't possibly do that while renting, and you can't generally do it in a syndicate unless it is a very special amicable one o 2 or 3 members. Add to that the chunk of one's life sunk into getting an IR (any IR) which is not just a pile of truly worthless exam swatting but also 50/55 hours of hammering NDBs etc until blue in the face (knowing fully that nobody flies like that in reality). Or going to the USA to avoid the European FAA IR hassles, but that largely trades one hassle for another; more so nowadays. Then throw in the cost of a reasonable IFR plane of say £100k plus (less if you don't mind £20k Annuals) and it's no wonder IR holders are mostly a bunch of obscessive types.

most PPL/IRs make almost every flight under IFR, right through to an IAP, even when VMC, whereas most IMCR holders don't. Funnily enough, when I once flew an ILS into Manston, in VMC, solo, I got told off by some self important instructor there who said an IAP in VMC always needs a safety pilot. I never went there after that.

The IR holder practice of always flying an IAP even under CAVOK comes from filing IFR enroute (for easy airspace access reasons, as much as anything else) and then flying an IAP is just standard ATC expectation, with a visual approach (which is an IFR procedure anyway) being offered sometimes (if the controller can speak enough English). It also helps logging the 6/6/ FAA IR approaches. But IMCR holders cannot do this abroad...

Timothy

6th Nov 2011, 19:49

Funnily enough, when I once flew an ILS into Manston, in VMC, solo, I got told off by some self important instructor there who said an IAP in VMC always needs a safety pilot. I never went there after that.
I would suggest having two words with him or her, and only one of them would be "off".

IFR is IFR. VMC is irrelevant.

Genghis the Engineer

6th Nov 2011, 21:56

Classic case, by the sound of it, of somebody who has seldom functioned outside the school environment, and thus has little grasp of real world flying.

Of course, an IAP in VMC demands see-and-avoid lookout, which I trust you did, as would any other sensible pilot. But that is absolutely not the same as a safety pilot (maybe it was in his club FOB and he didn't know the difference between that and the ANO?).

G

BEagle

6th Nov 2011, 22:21

Ah - the old 'safety pilot' argument!

Here's what the ANO says:

http://i14.photobucket.com/albums/a341/nw969/ANO23_24.jpg

From the ANO, 'simulated instrument flight conditions' means a flight during which mechanical or optical devices are used in order to reduce the field of vision or the range of visibility from the cockpit of the aircraft. Those bits of tin so beloved of the CAA or foggles, for example.

If you can find a legal definition of 'practice instrument approach', do tell us - there's nothing in the ANO as far as I'm aware.

The problem with flying IFR approaches in VMC outside CAS is that, if you're on your own head-down on the dials, no-one is looking out to spot other aircraft and take the relevant 'see and avoid' action in accordance with Rules of the Air. Although if you're using a decent autopilot, it'd be a different matter, of course. But in reality, the rule regarding 'practice instrument approaches' would be impossible to enforce.

flybymike

6th Nov 2011, 22:22

currency comes from frequent flying, which (in the long run) comes only from enjoyable flying, which in the long run rules out burger runs.

I've been doing burger runs for 28 years. How much longer do I have to keep doing them before I stop enjoying it?
Today's order bellowed out across the bar at Breighton, "TWO SAUSAGE AND EGG, AND A SAUSAGE FOR THE DOG" (No disrespect to the Missus...)

IO540

7th Nov 2011, 03:47

Beagle - 24 (2) (b) if interpreted as written would render illegal all instrument approaches flown solo where there is VMC above MDA/DA.

GTE - yes one needs to keep a lookout for traffic at all times when VMC, in CAS or (especially) OCAS. That does mean one is not going to be flying actually on instruments, the whole time, unless there is a competent safety pilot. But that also does not mean one cannot fly the procedure in terms of lateral and vertical navigation. In terms of instrument approach currency I think such approaches remain valuable because one can always practice IMC flight on separate occassions.

flybymike - I was referring to IFR :)

BEagle

7th Nov 2011, 07:43

BEagle - 24 (2) (b) if interpreted as written would render illegal all instrument approaches flown solo where there is VMC above MDA/DA.

It seems to stem from the days when people flew visual approaches unless they needed to fly an instrument approach because of weather. So the only people likely to be flying instrument approaches in VMC outside CAS were likely to be U/T.... Another ex-RAF policy? Certainly when I flew single pilot fast jets people would look astonished if you chose to fly an instrument approach when the weather didn't require it - radar-to-visual was the main option if you had to descend through cloud to VMC underneath, but then you would join visually off a VRIAB.

24 (2) (b) doesn't seem to cater for those who, for example, choose to fly an ILS in VMC at an aerodrome outside CAS - such as Manston? Or Biggin Hill when below the London TMA. It all depends upon the interpretation of the term 'practice'. If you are flying the ILS in gin-clear VMC with the intention to land, is that a 'practice approach' because the weather doesn't require you to fly an instrument approach? Or is a 'practice approach' only when you wish to go-around and land elsewhere?

flybymike

7th Nov 2011, 11:31

Just tell 'em you are not practising any more 'cos you know how to do it. Therefore perfectly legal....

Timothy

7th Nov 2011, 15:24

When I flew for a living it was company policy, written into the Ops Manual, that you did not cancel IFR, you flew the procedure every time, even in CAVOK. That was based on a long history of people changing their plans at the last minute and CFITing as a result, or making an approach to the wrong runway, or even street lights (the literature is full of such incidents.)

Our SOP was to fly the needles to minima and only then look up, every flight. That was partially to ensure that we remained utterly current at all times, even during long Summer months.

To say that you cannot, should not or must not fly an IFR procedure in VMC is palpable nonsense, in Class A, D or G.

Obviously if you are flying a procedure into a visual circuit you have to look out, particularly for reported traffic, but the main source of navigation information remains the instrument panel.

IO540

7th Nov 2011, 15:53

Our SOP was to fly the needles to minima and only then look up, every flight.

As you were flying multi crew jets (HS125) your co-pilot would have been looking out the whole time, which makes this rather different to doing it single-pilot.

In SP solo IFR one flies the IAP (if one is flying the IAP) but one looks out periodically after the point where one becomes visual with the runway.

Flying into street lights etc is the kind of thing which happens at night, and then flying the IAP more or less all the way down makes sense.

Cows getting bigger

7th Nov 2011, 16:43

Didn't someone have a rather nasty mid-air at Coventry a year or so back?

http://www.aaib.gov.uk/cms_resources.cfm?file=/8-2010%20G-BOLZ%20G-EYES.pdf

Mixing VFR and IFR has always been an interesting conundrum.

BEagle

7th Nov 2011, 16:59

Not really the same thing as a single pilot aircraft flown solo making an instrument approach in VMC outside CAS, I would venture......

Timothy

7th Nov 2011, 17:33

As you were flying multi crew jets (HS125) your co-pilot would have been looking out the whole time, which makes this rather different to doing it single-pilot.
Peter,

No-one has a higher opinion of your knowledge and experience than you do. Does it not occur to you that I know more about my biography than you do? I flew single crew piston twin air taxis for many years. I am not an idiot, even compared to you.

Whopity

7th Nov 2011, 18:03

englishal

7th Nov 2011, 18:09

The problem with flying IFR approaches in VMC outside CAS is that, if you're on your own head-down on the dials, no-one is looking out to spot other aircraft and take the relevant 'see and avoid' action in accordance with Rules of the Air. Although if you're using a decent autopilot, it'd be a different matter, of course. But in reality, the rule regarding 'practice instrument approaches' would be impossible to enforce
But that goes whether you are IFR and flying a "real" approach (in VMC) or VFR and flying a "practice" approach.

IO540

7th Nov 2011, 18:27

Also, in any conditions, in CAS even, there could be traffic there which isn't supposed to be there - as some have found out.

One is more likely to encounter it if the actual conditions are VMC, obviously, for that is the profile of the GA population, but one could be going down an ILS where from the FAF down to the DA one passes through 2 or 3 cloud layers, and somebody flying "VFR", or even just busting CAS, could be perfectly happy with themselves flying between the layers.

If you are head down all the way, and single pilot, and absolutely obeying the company rulebook and not even lifting the eyebrows to see if you are visual until the altimeter reads the DA (which I completely believe Timothy was doing, but it beggars belief that it would really be standard practice because it goes so much against human nature and self preservation) you are denying yourself the opportunity to spot some joker.

In VMC conditions you are chucking away the chance of spotting a runway incursion nice and early, or a helicopter doing something at 100ft AAL, etc.

But hey company policy is company policy no matter how weird. I once asked an instructor if when he was flying an NDB approach, and the ADF was indicating OK but a GPS was telling him he was about to die, his reply was he would trust the ADF.

Cows getting bigger

7th Nov 2011, 19:17

Beagle, I beg to differ. All the criteria were exactly the same with the 'advantage' of having a safety pilot doing the lookout. Somehow all concerned still managed to engineer a collision.

The point is quite obvious. Flying an instrument approach reduces effective lookout, irrespective of the flight rules/conditions. That reduction in lookout needs to be mitigated somehow, whether that is with a safety pilot, enhanced ATC procedures etc. FWIW, I think we all agree on that fact.

Timothy

7th Nov 2011, 22:36

What a wonderful argument against the proposed EIR!
Be careful what you wish for. If PT SOPs were applied to private flying, 99% of it would close down.

BEagle

8th Nov 2011, 06:51

What a wonderful argument against the proposed EIR!

Hardly, given that the privileges do not allow an IFR departure, arrival or approach:
Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating. Which includes SIDs and STARs, defined by the ANO as:

http://i14.photobucket.com/albums/a341/nw969/SID_STAR.jpg

Hence an EIR holder intending to fly IFR en-route will be required to depart under VFR until reaching his pre-planned VFR-to-IFR transition point, then fly the en-route element under IFR before reaching the IFR-to-VFR transition point and completing an entirely VFR arrival. Which is going to be rather more demanding in terms of flight planning than simply planning end-to-end IFR - and which may confuse the heck out of an air trafficker unused to such things.

If there's no STAR and the EIR holder is following radar vectors, he must fly VFR before reaching the approach fix:
If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).

Quite how easy it will be to convince ATC that you may not accept vectors to final, I'm not sure. Vectors to the overhead, to join visually?

N.B. My quotes are from NPA 2011-16. The use of 'should' has already been pointed out to EASA to be incorrect; however, it seems that their own rules don't allow 'shall' in an AMC....:\ So they've said that they will find a way of ensuring that these will become mandatory requirements in the final Opinion.

Timothy

8th Nov 2011, 07:26

and which may confuse the heck out of an air trafficker unused to such things.
Which would confuse an air trafficker more:

An aircraft reaches an airways point, requests to leave controlled airspace by descent and then, a few minutes later turns up at a VRP asking for VFR entry (both completely normal, recognised aviation practice) or
Aircraft flies a STAR, arrives at the IAF and says "sorry guys, here I am in the middle of an IFR procedure but I'm VFR and can go no further IFR; what are you going to do about it?"

The answer seems obvious.

Genghis the Engineer

8th Nov 2011, 08:02

A thought on a dilema that seems to be appearing from this debate. Take me for an example - I fly a moderate 90ish hours per year - so pretty current in general terms, am IMC qualified and current, but by most standards am a very inexperienced instrument pilot.

So, I turn up at an airfield with a couple of available IAPs; in adequate or good visual conditions. This happens reasonably regularly. Indeed, I tend to try and avoid flying when the weather is particularly poor, because it's less fun and usually I don't need to.

So, if every time I can, I fly a visual approach, the result is that I fly a genuine IAP 2-3 times per year.

On the other hand, fly an IAP when I can - which perhaps means I fly an average of 1-2 a month. Perhaps degrade my instrument flying performance a bit by maintaining a good lookout, or if I have a passenger give them a lookout role. This is certainly the approach I'm taking with my flying at the moment (although many airports do not seem to see why I want an IAP if the conditions are good for a visual approach, as others have mentioned).

Now, take the day I'm on a long trip into somewhere, the weather has deteriorated, and my route back is around my IMC minima - say 600ft cloudbase with an available ILS, and 2000m RVR. This is the day I really need my instrument flying skills.

If I've been flying an IAP a couple of times per year, I'm rusty, working extremely hard, and the potential for me to screw up is on the high side.

If I've been flying a couple per month, I'm sharper, more current, working less hard, and more likely to get the IAP right.

This to me makes a strong case for taking an IAP when one is available, to stay sharp, for the day you really require it. It is also an argument against the philosophy of the EIR where the "emergency instrument procedure" allowed for in the EASA philosophy will seldom if ever be practiced (and if it's in the annual IRT, will cause EIR holders to end up spending lots of money on training every year to get themselves back to test standard for their practice emergency IAP since they've had no ability to practice it otherwise).

Allow at-least an EIR to accept SIDs and IAPs when they can do so whilst remaining VMC below MSA, that way when they really need to make an IAP, there's a fighting chance they'll remember how to do it!

You may of-course get stung for approach fees - but I'm willing to bet that those approach fees will add up to less than the remedial training to get through the IRT/IMCRT renewal if the pilot hasn't been practicing.

G

IO540

8th Nov 2011, 08:12

This to me makes a strong case for taking an IAP when one is available,Very much agree.

Allow at-least an EIR to accept STARs and IAPs when they can do so whilst remaining VMCI would like to think that the ban on arrival and approach procedures even in VMC is a c0ckup.

My main beef with the otherwise useful EIR proposal is that it bans SIDs and STARs. Specifically, it means you gave to cancel IFR at or before the last enroute waypoint, which means that your legal preflight planning has to include a verification of VFR conditions at that waypoint, for which there is no obvious process, internet or no internet. I also think it will confuse the hell out of ATC, not least because that last waypoint is prob99 going to be in CAS, and at an altitude at which VFR traffic would not be desired in many/most countries in Europe.

As a side point, flying conventional-navaid IAPs is a whole lot easier if you have a moving map GPS ;)

Timothy

8th Nov 2011, 08:13

Allow at-least an EIR to accept STARs and IAPs when they can do so whilst remaining VMC, that way when they really need to make an IAP, there's a fighting chance they'll remember how to do it!
What IAP applicable skills would be honed by flying SIDs and STARs which are not honed by flying airways (including climbs and descents in and out of CA)?

I am writing an article as we speak (actually, writing this posting is just another procrastination tactic not to get back to it) about zero-zero landings.

I was taught (by one example) how to do a zero-zero landing in June 1986. I needed to do one in April 2008, 22 years later. I did so quite effectively.

The requirement to do a zero-zero landing by an experienced IR who has got caught out cannot be much different from the requirement for an EIR to fly an instrument approach, or SRA, to, say, 800' because he has got caught out. (let's not think that an EIR has got so caught out that the weather has gone from above the MSA to below minima, that's daft.)

GeeWhizz

8th Nov 2011, 08:15

Timothy

8th Nov 2011, 08:21

a question from a slightly different stance for those who have scrutinised the NPA: if an IMCR holder were to add an EIR to their repertoire, would the combined privileges equal those of a full IR holder flying solely in the UK? It seems possible to depart Southern Europe in VFR, fly IFR en-route, then complete an IAP in the UK.
...except at LHR and the Channel Islands.

For a UK pilot, having an IMCR and an EIR would be a great combination, because, as well as being IAP legal in the UK, when the weather was bad in Germany or France, he would still have the skills to perform an instrument approach, albeit illegally.

However, some thought has to be given to the pilots of 26 other countries! maybe they should all pile over here and get a UK IMCR before April :p

IO540

8th Nov 2011, 08:48

A question from a slightly different stance for those who have scrutinised the NPA: if an IMCR holder were to add an EIR to their repertoire, would the combined privileges equal those of a full IR holder flying solely in the UK (notwithstanding visibility and descent minima)? It seems possible to depart Southern Europe in VFR, fly IFR en-route, then complete an IAP in the UK.

It should work, so long as you can file an IFR routing via Eurocontrol such that the terminating waypoint of the enroute section is not in UK Class A-C, because the IMCR does not give you IFR privileges for Class A-C.

You will have to file a route which terminates in Class D, or OCAS, basically.

The ability to do this depends on how strictly Eurocontrol enforce the last waypoint of the enroute section connecting to the first waypoint of the STAR. In the UK, this seems pretty loose, and a DCT to a waypoint further down the STAR ought to work provided it is shorter than 50nm (100nm if below FL100).

If landing at an OCAS airport, there isn't going to be a formal STAR anyway, so the route can just end with a DCT or two as desired.

I have just had a quick look at Bournemouth (Class D) and e.g. the arrivals from the south east are no problem either, as no explicit enroute terminator waypoint is given; you can seemingly just pick any of SAM, GWC, CAMRA, WAFFU, etc. Cardiff appears similar.

Flight Plan Pro (http://flightplanpro.eu/Home.html) is the tool I use for Eurocontrol routings. It's free, so grab a copy and have a play. The lowest airway level worth trying is FL070 and FL100 generally works a lot better. I always go for min FL090, desired FL140, max FL190.

If you want a web-only facility (which can run on a smartphone, etc) then Rocketroute (http://www.rocketroute.com/) gives you the same routing features as FPP. RR uses the same routing software as FPP (written by the same person - a poster here :) ).

For those who develop their routings using a separate tool (such as FPP) there is EuroFPL (http://www.eurofpl.eu/) which is what I use. They offer the Eurocontrol "route suggest" facility which is usually OK, but the FPP routes tend to be better optimised.

Timothy

8th Nov 2011, 09:15

For those who develop their routings using a separate tool (such as FPP) there is EuroFPL which is what I use. They offer the Eurocontrol "route suggest" facility which is usually OK, but the FPP routes tend to be better optimised.
EuroFPL also remembers successful routings made by other people, which means that between most airfield pairs there is a choice of half a dozen routings found by others, each declaring the percentage distance more than GC.

I must say that I tried FPP and didn't find that it worked (it was very buggy, that might have improved since) whereas EuroFPL usually gets me around 105% - 115% GC with no difficulty.

S-Works

8th Nov 2011, 09:47

Quote:
As you were flying multi crew jets (HS125) your co-pilot would have been looking out the whole time, which makes this rather different to doing it single-pilot.

Peter,

No-one has a higher opinion of your knowledge and experience than you do. Does it not occur to you that I know more about my biography than you do? I flew single crew piston twin air taxis for many years. I am not an idiot, even compared to you.

Some days its worth coming on here...... :p:p:p

Timothy

8th Nov 2011, 09:50

Steve,

I beg you not to turn this very useful thread into a Holy War.

S-Works

8th Nov 2011, 11:18

Sorry, I jihad to mention it......

englishal

8th Nov 2011, 17:07

Just a thought...

I fly an N reg. I hold an FAA IR. I hold a JAA PPL with IMCr.

What I understand is the EIR will be given in exchange for an FAA IR. I hold and IMC which will be grandfathered.

So I see the problem with private N reg and IFR ops has now gone away - I can fly the N reg using the FAA certificate (required), I can fly IFR IAPs in the UK using my IMC (required due to stupid rules), I can fly IFR IN CLASS A AIRSPACE in Euroland due to the EIR (and FAA IR), I can fly IFR anywhere in the world due to FAA IR.

Suddenly there seems very few restrictions, other than perhaps I can't fly an ILS in France.....But actually I would do that anyway due to my Mexican visa which says "this person is a temporary resident of Mexico" on the back....so all of the above is irrelevant?

Am I correct?! ;)

GeeWhizz

8th Nov 2011, 17:15

Cheers guys, it was something I've been pondering over for a few weeks but with the sensitivity of IR vs IMCR/EIR I didn't want to upset anyone. Took a deep breath and cringed before reading your replies in fact!

To be honest it'll be at least another year before I fly anything that has a service ceiling above 13-14000ft without thinking about cruising at FL140. That said, I'm beginning to see the usefulness of the EIR if it would be possible to fly through or cross the low-alt airways flying an East/West track in DTY or TNT areas for example. Perhaps a solid cloud base base of 3-4000ft on a day when 'ginners' VMC on top at 6-8000ft would be more useful? It would only take 20-30nm max in a straight line, and hopefully my 'spamcan' wouldn't cause any problems with the AT ships.

As for filing a FPL, I like to think I'm a dab hand with ERCs, AFPEX and FPL addressing. Its astonishing how many PPLs I hear having trouble with AFPEX FPLs to hop across the Channel because they are trying to put VRPs in the route field rather than as RMK in F18. OK OK a bright spark will turn up here shortly to spout something about the full FPL not being visible to all. Which is true for Centre and Information agencies as their electronic flight strip system automatically displays the route with essential details. The full FPL has to be requested by exception which is also available. The full plan is also read by Dep, Dest, Altns, and Originator by default too.

IO540, I'll definitely investigate FPP and Rocketroute see how they compare. Although in case of cerebral flatulence I have contacts at Brussels as a last resort (also 'IFPS route changes accepted' in F18 usually works if the FPL can't be auto ACK'd and goes manual) ;)

Thanks again!

IO540

8th Nov 2011, 18:13

What I understand is the EIR will be given in exchange for an FAA IRSpeaking of the FCL-008 IR (now called the CBM IR), an ICAO IR holder will be exempted from the mandatory flight training (which for an ab initio IR student will be 40hrs min instrument time of which 10hrs min must be with an IR instructor) but will still have to sit all the exams. The exams are not defined yet (and the proposed content is particularly vulnerable to gold plating at present) but there will likely be several of them, with a useful reduction from the present 7-exam JAA IR garbage volume. And you need to pass the flight test with the IR examiner.

AFAIK the above is true for both the EIR and the CBM IR.

All in all, the proposed conversion is not all that different to the present 15hr IR conversion route, once you consider that the present 7 exams are supported by a reasonably complete question bank and, if you do it all via CATS, you can just hammer the QB and never have to open the almost totally irrelevant study material. The present 15hrs minimum dual flying time is probably what most existing IFR pilots will need to pass the flight test with the traditional IR examiner (VOR, NDB, etc stuff), anyway. That is basically why I am doing the IR conversion now, rather than waiting.

Plus you will need the CAA Class 1 medical, or the Class 2 with the Class 1 audiogram.

To be honest it'll be at least another year before I fly anything that has a service ceiling above 13-14000ft without thinking about cruising at FL140For getting reasonably good routes in Europe, you don't need FL140. It is a matter of where the cloud tops end up. In most weather in between fronts, they are substantially lower than that. So e.g. a PA28-181 will be quite fine, but not a C152. In reasonable conditions one can often do the whole lot at FL100. Over the Alps, etc, however, some of the airway MEAs are FL140, 160 or even 180. Oxygen is however extremely useful. Some notes on how one can do it can be found here (http://www.peter2000.co.uk/aviation/).

As for filing a FPL, I like to think I'm a dab hand with ERCs, AFPEX and FPL addressingIn that case you will find Eurocontrol IFR easy enough :)

also 'IFPS route changes accepted' in F18 usually works if the FPL can't be auto ACK'd and goes manualThe drawback of doing it that way is that you are handed a route, often at the last minute (if doing a late filing), which you have not planned, have not loaded into the GPS, so you don't know what route to fly in case of lost comms etc.

The new route will be communicated to you from the filing agency, usually to your phone, so you have to pick it out of there, convert it to waypoints to load into the GPS, etc.

And if you file the FP traditionally (handing it in at the tower) the new route will never be communicated to you so you have to wonder where ATC will send you next.

Admittedly a lot of pilots, especially those totally baffled by the Eurocontrol tech-boffin system, use the 'reroute accepted' and get away with it well enough on the day, but if you can generate a valid route yourself then you will be much better prepared when you get airborne.

Fuji Abound

8th Nov 2011, 18:35

I posted on this subject previously but perhaps my thoughts are worth repeating.

I dont understand the magic of the FAF. The CAA took the view that IMCr holders might struggle to fly to the required tolerances close to the ground. In consequence they recommended IMCr holders adopt a higher DH that IR holders. In that there is sense. The pilot has been restricted by a parameter which is directly related to the skiils he is required to excercise. On the other hand the FAF is not asscoiated with any parameter of which I am aware in the same way. It could be overhead the airfield at 1,600 feet or it could be ten miles from the airfield at 4,000 feet.

I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.

In reality few arrivals will be procedural these days, and for most of us wanting an easy life we will routinely accept vectors. It also seems to be worrying that a pilot is aqualified to fly airways cant be trusted to accurately fly vectors in IMC to a reasonable tolerance.

For these reasons using the FAF as the point of defining where the pilot's skills dont correspond with the task in hand doesnt make a great deal of sense.

If the pilot is to be restricted, he should be restricted by his actual skill set.

My experience is that many pilots struggle to fly a complicated procedural approach. It is also my experience that many pilots struggle to fly the final part of an ILS accurately. However, pilots are pretty good at accepting vectors.

For all of these reasons it seems to me than an EIR holder should be allowed to accept vectors to the top of the glide slope. Whether he should be allowed to continue some way down the glide slop is debatable and would depend upon how much ILS training was included in the syllabus. If it was felt that he should not continue down the G/S unless visual at the top of the G/S I dont see this an issue. The pilot would fly the missed and AT would be well accustomed to pilots going missed albeit usually from a lower level.

It could be argued that if the pilot went missed at the top of the G/S he would now have to fly the missed procedure for which his skill set was lacking. Well that is where an approach ban could be useful. In other words if the METAR wasnt giving a cloudbase above the top of the G/S the pilot would be required to divert - simple and clear, and reliant on an accurate and current definition of the conditions, unlike deciding what the cloudbase might be at an FAF ten miles from the airports based on the airport METAR or the area forecast.

In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.

GeeWhizz

8th Nov 2011, 18:57

I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.

I agree with half of this. Yes the FAF is where things become more complex and screwing up may be more likely. But I think an EIR would be realistically better suited to terminating IFR at the IAF; personally I think this is where an arrival procedure begins yet its far enough out procedurally to be manageable on basic skills. Perhaps the EIR holder should aim to become VFR/VMC at a defined position after passing the IAF during the intermediate approach phase before the FAF or FAP? I don't know the answer, just a thought.

In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.

A fine idea that is sensible. Further thinking reminded me of a comment someone made either earlier within this thread or maybe another, about the radar to vis procedure used by military types. The aircraft is vectored to a height/altitude according to the lowest possible vectoring level for the specific airfield, roughly 1nm dead side in order to become visual with the field and fly a dead side join into the circuit. This also happens whilst other aircraft perform IAPs to the same runway. Not sure if this should be made standard for EIR arrivals? Essentially a vectored cloud break descent into VMC (carried out anywhere enroute potentially) to circuit height.

Timothy

8th Nov 2011, 21:10

I'll repeat my earlier point. What is ATC supposed to do with someone who reaches the IAF (or FAF) expecting to be VMC who isn't? Presumably push them into the Missed Approach? That means that most traffic will be descending to 200' to a successful landing and a few will be clogging the system by flying from the FAF to MAP, at 2,500' then starting a missed approach already 2,300' too high...it's horrible to contemplate.

If you dump them out of airways just far enough from the zone boundary to descend outside controlled airspace such that they can call visual for a visual approach it makes much more sense.

If they reach MSA while still in IMC they then have to assess their options, just like someone going to a VFR field today does. They might decide to push it, because they are certain of their position, or they might fly out to sea to descend, or they might declare an emergency and get shepherded down an approach.

These are all things we do at the moment and require no new regulation, familiarisation or training for ATCOs.

You know it makes sense!

Fuji Abound

8th Nov 2011, 21:51

Timothy

I cant agree. Dumping a pilot out of the airways is never a good idea. He finds himself with a fragmented service at best ocas and possibly no service at all scrambling around low level with potentially no way of getting back into the system and working out a diversion on the fly. If the belief is eir pilots are some way short of the ir skill set this is a recipe for disaster.

No the pilot needs a reliable point to which they can descend pretty much assured of a further visual descent thereafter. Some point, any point, in the procedure to which they can be vectored would work as long as that point is within reason with the cone of the airport metar. In that much 9 times out of ten the pilot knows whether or not he can complete the procedure in vmc. If he cant before being dumped he can continue within the system to a suitable alternative.

I dont agree this would cause a problem. It is not that unusual for a pilot to request a visual approach once in vmc at a point in the procedure. I suspect most atc would be able to handle some traffic doing so. Moreover in reality i dont think any of use believe there will be droves of pilots going to the busy commercial airports as a result of the eir. Most pilots stay away because of the cost and hassle as it is - that will not change. The mid sized regional airports are hardly pushed it seems to me and have the flexibility to deal with the odd eir requesting vectors to descend and brk for a visual approach.

Timothy

8th Nov 2011, 22:12

Genghis the Engineer

9th Nov 2011, 06:19

Timothy - I'm not defending the EIR approach, which I disagree with, but presumably the pilot, just as he/she would when descending to DH and finding themselves still in IMC, will divert to their alternate? The difference is that they no longer have to fly the missed approach procedure.

G

Timothy

9th Nov 2011, 06:57

I'm not defending the EIR approach, which I disagree with, but presumably the pilot, just as he/she would when descending to DH and finding themselves still in IMC, will divert to their alternate? The difference is that they no longer have to fly the missed approach procedure
But if they don't fly the MA what do they fly? That is my point.

Fuji Abound

9th Nov 2011, 07:43

Timothy to be fair it was you who introduced the dumping concept.

This implies returning from france at fl65 to be told by london to continue with london info because you are too low for an airways clearance. Descending ocas for a class g arrival is a diiferent matter. You have not exactly be dumped but have elected to leave the system for reasons of necessity.

Never the less i dont follow your concern about the pilot flying the ma. As matters stand if the pilot is not visual by the faf he is going elsewhere. At that point he is some way away from the final approach track so the ma is hardly appropriate. As he is ocas he would presumably inform at that he was not visual at the faf and would continue on heading x with a request to climb to y and depart own navigation on a heading of z for his diversion.

In my opinion i come back to the point i made earlier it is just daft that a pilot would be persuaded to leave cas on the strength of a metar for a descent to a point that might be miles away from the airfield. If on the other hand he knew the metar coincided with weather at the point at which he was descending he would make a sensible judgement call as to whether or not he expected to be visual by that point and if he didnt before leaving the comfort of cas would go elsewhere.

Unless you know differently it seems to me most airports with an iap in class g have almost no traffic when the weather is poor and i doubt if it is that poor the eir holder will have much chance of being visual by the faf. Never the less if he elects to prove the metar wrong i doubt he will cause at too many problems.

GeeWhizz

9th Nov 2011, 07:58

I'll repeat my earlier point. What is ATC supposed to do with someone who reaches the IAF (or FAF) expecting to be VMC who isn't? Presumably push them into the Missed Approach?

The way I understand the EIR concept is that an arrival is to be made VFR in VMC. Is it not logical to expect that if a pilot is permitted to get into and fly within IMC, that he/she cannot, at a suitable time, organise a descent to return to VMC? It suggests a little extra planning would be required, which realistically isn't too far from what IMCR or VFR only pilots are doing already. Should the met forecast not agree with the limitations of our ratings we don't fly the route or flight, or we do something else.

If the weather is different from the met office fairy tale then of course a diversion to an aerodrome maintaining VMC would be sensible. I agree that allowing an EIR to descend to 2500' or whatever to 'go missed' is silly, pointless and dangerous. The EIR NPA caveat of having an alternate field planned that is VMC should be mandatory (it probably already is banter away!) in this sense. Perhaps even to the extent that the weather minima must be VMC for the hour prior to landing +1. I was going to suggest CAVOK but enforcing this would render the EIR useless in general.

I'm sure there are very few of us actually supporting it, but the EIR seems inevitable; recent debates are on how this rating could work rather than fighting against it.

Fuji Abound

9th Nov 2011, 08:06

I think the eir will exist and i hope it will evolve into something better, assuming it is found to have shortcomings.

BackPacker

9th Nov 2011, 09:15

We are not talking about "dumping". We are talking about the perfectly normal procedure of an aircraft leaving controlled airspace either laterally or, more commonly, by descent. It is what every aircraft bound for an airfield in Class G does at the moment. It is SOP.

Timothy, that may well be SOP in the UK, where there are large swaths of class G, extending well above the MSA. But that's not true of large portions of the rest of Europe, where you may find large swaths of class E, with the bottom well below the MSA.

So how is this going to work then, assuming the cloudbase is at or below the MSA? There is no written IFR procedure for a descent to VMC below the MSA, with the sole exception of the current approach procedures themselves. Or are you going to assume that ATC is going to let you descend in IMC and in controlled airspace, below the MSA, somewhere randomly off-airport (possibly in a non-radar environment)? Or are you going to assume that specific off-airport descent procedures will be designed for the benefit of EIR holders?

I agree with Fuji. The EIR holder has to be able to work in the current system of airways, MSA and instrument approaches. If the EIR holder is not deemed sufficiently proficient to fly an instrument approach to published minima, then higher minima need to be establised (either expressed as an AAL, or the IAF, or the FAF, or the top of the glideslope, whatever) but laterally the only location where the EIR holder can fly below the MSA is on the instrument approach. And if they don't reach VMC by the time they reach whatever minima are established for them, they fly the missed approach procedure to get back above the MSA.

Particularly in a non-radar environment there is no way that ATC can handle anything other than that. Except in situations where airspace is structured like the UK, where ATC can let you descend above the MSA to some place outside controlled airspace, and then take their hands off you. But you can hardly call that "handling".

mad_jock

9th Nov 2011, 09:38

This is assuming that the EIR is going to be using the same approaches as the IR traffic.

It would be relatively simple to design a cloud break procedure to comply with the EIR rules which then delivers the aircraft to some point which is away from IR traffic and will allow the EIR to then come in VFR without getting in the way.

It would only take one procedure and as it will be above MSa it wouldn't require expensive surveying etc to design.

BackPacker

9th Nov 2011, 10:12

It would only take one procedure and as it will be above MSa it wouldn't require expensive surveying etc to design.

I may be daft but why would you need a separate procedure to descend to the MSA? You can just descend on track to the MSA, can you?

Anyway, adding an EIR cloud-break procedure for each of the thousands of airports in Europe is still going to be a lot of money. And I don't think it's far from trivial as there has to be some sort of STAR towards that procedure from all directions, and some sort of missed-approach procedure that brings you back into the airways (like a SID).

And obviously those STARs, the cloud-break procedure itself and the missed approach procedure all need to either tie-in neatly, or remain totally separate from the current full-IR procedures, so that they can be executed in parallel or sequential, without causing conflicts, even in non-radar situations.

IO540

9th Nov 2011, 10:25

Nobody is going to be designing special procedures for GA. It's simply not going to happen in Europe, in much of which GA is all but nonexistent anyway.

This has been done many times here but the main issues in the "IFR department" are not aviation related but political.

Being political does not make them any less real or problematic, of course.

There is also a lot of emotion around the whole subject of IFR, nearly all of which is not based on any safety data and is propagated by old prejudices. Nearly all commercial aviation runs in the IFR system, and the amount of work one has to do to become an ATP makes everybody involved very guarded about any newcomers into the system who appear to have done less to get in than the present incumbents.

For European IFR, as approved by the European axe grinders, there are certain things which are absolutely not negotiable:

1) Whatever you do, a "Euro IR" must not be like the FAA IR. "FAA", "USA" etc are dirty words in European aviation regulation, and in most of the training system for both commercial pilots and ATCOs. So any new IR has to differ in key respects. But EASA has ostensibly nailed its flag to the "ICAO" mast and while this is the key factor here which is enabling progress, one can push this only so far.

2) One is not allowed to state the truth that the UK IMCR is a full IR in all but name, and only the UK's extensive Class A separates the "amateurs" from the "pros". An IMCR holder who has been trained by a real IFR-flying instructor will be able to fly any published approach plate for any airport in the world. SIDs and STARs are not covered but are relative trivia. Nearly the entire difference between the IMCR and the IR is the currency of the holder and his aircraft capability and equipment, but that is nothing to do with the bits of paper. But the only other Euro country with lots of Class A is Italy, so the IMCR concept is not transportable to the rest of Europe because it would be a full IR in most of it. The 1800m vis is a non-issue most of the time (it is practically fog). I know the JAA IR flight test is harder than the IMCR flight test, but the JAA IR flight test is also a lot easier in say Spain or Greece than it is in the UK...

3) Speaking of the EIR, if you got too close to allowing approaches, it would be a full IR, but you can't do that :)

I have no inside track on what is going to happen, but I suspect that the EIR may get tossed into the melting pot at the end, as a quid pro quo to get the CBM IR accepted. One does the same thing in Planning applications ;) In that respect, the EIR is vitally important, otherwise any difficulties on the CBM IR will result in its termination, and in the continuation of the present ridiculous 50/55hr JAA IR route which very very few private pilots have been doing since JAA came along in 1999 (most went N-reg).

There is a long way to go on this stuff. The CBM IR is going to become a political hot potato for some other reasons.

mad_jock

9th Nov 2011, 11:20

Yes you could but that would then get in the way of the other procedures/ vectoring.

Just bung a line off from the end point of a star to some place that they arn't going to get in the way and thats your procedure designed. It won't cost a fortune.

I agree its political as most airports and airlines don't want slow IFR traffic getting in the way of the commercial inbounds. They will suffer it enroute because the levels being used in general aren't the ones they want. I think most will put up with getting you to the end of a star or getting somewhere visual then hopefully you will dissappear of to some other airport without any approach aids. If not you are stuck orbiting until they have a hole to get you in.

IO540

9th Nov 2011, 13:30

It's not even political in any operational sense.

IFR GA has never been an operational issue in Europe, because

- ATC nearly always give jets traffic total priority on getting airborne, even if it means keeping light GA at the hold for an hour

- the lower airways in Europe are practically devoid of traffic (easy to do a 700nm leg without getting visual with another plane, of any kind, within a few k feet in altitude)

- the Eurocontrol routings keep lower airways traffic well away from terminal areas

- ATC keep it well away from other traffic in terminal areas, which is not hard because the climb and descent performance of the two is very different

- it goes mostly to different airports, because the big ones have set up "mandatory handling" cartels with silly pricing

- there is very little of it, due to poor utility value of GA in Europe

The politics are to do with professional pilot status (tied to the IR, instead of being tied to the ATPL like it is in the USA), FTO profits (or lack of them, presently), and stuff like that.

flybymike

9th Nov 2011, 14:20

even if it means keeping light GA at the hold for an hour

I think my record is about 40 minutes. Can anyone improve on that?

IO540

9th Nov 2011, 14:44

You could try Valencia... it's fun to hear the Ryanair pilots say to each other "welcome to the 3rd world of Europe" :)

BackPacker

9th Nov 2011, 14:59

I think my record is about 40 minutes. Can anyone improve on that?

I once spent 20 minutes waiting just to cross the runway. Because ATC was in the habit of giving landing clearances 4 nm out. Does that count too?

Genghis the Engineer

9th Nov 2011, 15:30

35 minutes, so not quite at the lead. March 2006, Coventry, whilst they reconfigured the runway for arrival of whatever budget airline they had operating there at the time. (BMI?)

G

GeeWhizz

9th Nov 2011, 18:48

Only been held twice. The first was 30 mins along a very thin taxiway where a CPL/ME student was doing run ups; you could have defined the concept of 'Air Rage' by my vocalisations!:mad:

The second was only 20 mins at the hold due to a large jet flying an 'ILS against the stream to circle to land' manoeuvre. Interesting to watch so no grumbles.

Timothy

10th Nov 2011, 07:56

My worst was being on minimum fuel and being told by LHR that the hold would be at least 40 minutes, so shutting down, and then being asked "are you ready immediate?"

The answer was yes, of course. The last call in the flight deck on the ground was "Take-off checks complete - rotate!"

swflyer

11th Nov 2011, 19:50

CAD test - This is amazing news. I just saw an example on You Tube and while of course you can't trust the colours on You Tube, it was fascinating to see how much I could follow. How long can you "miss" in the test? Any idea?

Deadline - My understanding now, if I understand it right, is that the IMC finishes on the 8th April 2012 for good and that if you want to get the rating you must have your rating approved and added by the CAA by that date. Also AOPA made a comment that I found, that said that EASA had confirmed grandfather rights for IMC holders so I'm hoping that is correct.

As always though, isn't it frustrating how hard it is to find simple answers! Thank you guys, without there being such a great community no one would be able to work out anything.

sherburn2LA

11th Nov 2011, 20:40

is it correct that the IMC will need to have a current renewal at the 8th April date ?

IO540

11th Nov 2011, 20:45

I don't think anybody really knows, but having a recently validated IMCR in April 2012 would not be a bad idea.

In this business, much hangs on grandfather privileges and various other paper collection devices.

Flying itself is relatively easy :)

BillieBob

11th Nov 2011, 20:55

....EASA had confirmed grandfather rights for IMC holders....In the world of EASA nothing is 'confirmed' until it is issued in print (and grandfather rights for IMCR holders isn't). Generally speaking, EASA bureaucrats are a bunch of corrupt liars who will say anything to pacify the angry mob.
is it correct that the IMC will need to have a current renewal at the 8th April date? Again, nobody knows because nothing is in print. However, on the basis that EASA will not convert a National ATPL into an EASA ATPL unless it has a valid multi-pilot type rating attached, my guess is that, if there are to be grandfather rights, they will apply only to valid ratings.

Whopity

11th Nov 2011, 22:13

What is quite clear from the latest NPA is that in order to obtain "grandfather rights" the holder of the rating will have to meet the JAA IR standard It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges.A high uniform level of safety is ensured by requiring the applicants to pass exactly the same skill test as established already for the IR in Part-FCL.As IMC rated pilots are not trained to the IR standard, very few will achieve any grandfather rights without spending a considerable amount of money. The Test will be conducted by an IRE, who charge twice as much as existing PPL FEs, and be twice as frequent (12 as opposed to 25 months), resulting in a price hype by a factor of 4 to begin with.

Timothy

11th Nov 2011, 22:33

Whopity,

I think that your argument is entirely misguided. The authorities are finding a convenient way to package IMCR privileges into a constrained EASA world.

The IMCR will remain the IMCR in all but name.

As I understand it, all IMCRs, current or not, will be grandfathered. But any which way, the CAA has no history of applying a new FCL regime at zero notice. If they say that IMCRs have to valid on a certain day to be grandfathered, there will be enough notice for people to get renewed by that date.

What I find a bit sad about all this paranoia is that the CAA has never behaved as dishonourably as posters are suggesting. Essentially they support the IMCR, and are doing their best to retain it. EASA are co-operating in that venture. Why do we have this constant background noise of "they must be out to cheat us"?

The officials in the CAA are probably reading this thread. They are real people, with homes and families, trying to do their jobs in our best interests despite EASA pressure. Demonising them like this must be making them wonder why they bother.

Fuji Abound

11th Nov 2011, 22:39

Timothy not only did that need saying but it was well said.

Never the less we must not drop our guard.

GeeWhizz

11th Nov 2011, 23:25

Timothy you've got a great point on this. Although perhaps rather than all of this background noise of "they must be out to cheat us" its more a plea for information that is less than forthcoming. I would much prefer some sort forum where the CAA clearly and frequently provides updates on this matter. Understandably the EASA changes involve a lot more than GA and the IMCR; but a little information or a statement on the CAAs intent would keep many of us warm and fuzzy.

Now, sit comfortably with a stiff tipple because I fear what I'm about to suggest is probably going to upset the apple carts of some readers...

Quoted by Whopity
The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held.
(My emphasis)

To me this reads that the IMCR will become an 'IR-Restricted'. This term has been bandied about previously and probably will be again. So I feel a comparison is needed (and this is where unpopularity begins).

Not ideal but the best way I can think of comparing this is to the FI rating. An FI is an FI; with or without restrictions. For example, FIs may have 'no night' or 'no applied instrument'. Does this mean that they cannot instruct? No. In the sense of IMCR/IRs the restrictions would reflect what we are already doing, UK OCAS only, IAPs permitted UK only.

Posted by IO540
One is not allowed to state the truth that the UK IMCR is a full IR in all but name, and only the UK's extensive Class A separates the "amateurs" from the "pros". An IMCR holder who has been trained by a real IFR-flying instructor will be able to fly any published approach plate for any airport in the world. SIDs and STARs are not covered but are relative trivia. Nearly the entire difference between the IMCR and the IR is the currency of the holder and his aircraft capability and equipment, but that is nothing to do with the bits of paper.

Posted by Whopity
As IMC rated pilots are not trained to the IR standard

IO540 has stated here what I was afraid of saying. Both the IMCR and IR are similar. It is the extra 35 hours required for a full IR that causes contention, and of course 35 hours can be completed in a sim! However IMCRs are not for the commercial airline crew. They are for the GA community that want to be able to fly on PPLs when the weather is less than perfect to hour-build? Go places? Travel for work? As an addition to IO540s comment above, I was taught SIDs, STARs (as far as possible, and actually my approach for the IMC flight test was a STAR), and flew to an IR standard for probably 70% of the training, a credit to my instructor and what a fantastic job he did! I like to think every instructor that teaches something so safety critical, leaves questions of training standards irrelevant. The content of the IR is all encompassing, and so it should be if you want to sit in front of 300 paying passengers or more, 6 miles skyward, hurtling along at 500mph, without looking where you are going! ;)

englishal

12th Nov 2011, 00:37

The officials in the CAA are probably reading this thread. They are real people, with homes and families, trying to do their jobs in our best interests despite EASA pressure. Demonising them like this must be making them wonder why they bother.
Although...I had a conversation recently with someone on the political scene and his view was...."it is not always the European rules that are barking mad, but the way the British interpret them".

I can see his point. It seems to me that if the French can just pull an IR out of thin air just because they wish to (apparently without endless months of committees, debates, meetings etc...)and seemingly get no complaints from Europe, then the CAA could have just said from day 1) "The IMCR will be grandfathered for existing holders" or "The IMCR will remain in place for use in UK airspace". Maybe the French weren't following the rules to the letter, but so what.

Anyway I am not complaining, I have a valid IMCr, based on a foreign IR.

421C

12th Nov 2011, 07:04

What is quite clear from the latest NPA is that in order to obtain "grandfather rights" the holder of the rating will have to meet the JAA IR standard
No, quite the opposite is clear to me from the NPA. An IMCr holder will need to have an IMCr (probably a valid one) in order to be issued a restricted IR granting IMCr privileges in UK airspace.

The content of the IR is all encompassing, and so it should be if you want to sit in front of 300 paying passengers or more, 6 miles skyward, hurtling along at 500mph, without looking where you are going
The IR has no content specific to flying jets/6miles up/500mph/300pax any more than the IMCr has. You can be trained and tested for the IR on a Cessna 150.

It seems to me that if the French can just pull an IR out of thin air just because they wish to (apparently without endless months of committees, debates, meetings etc...)and seemingly get no complaints from Europe
That's because the new French IR is not an EASA FCL qualification, just as the IMCr isn't. They won't be valid under EASA FCL and will need a conversion deal also. The UK could also pull such an IR out of thin air too, at present, because EASA FCL is still not in force and won't be until next spring with the variations transition periods following.

BillieBob

12th Nov 2011, 08:29

What I find a bit sad about all this paranoia is that the CAA has never behaved as dishonourably as posters are suggesting.I'm not aware that the CAA has been accused of acting dishonourably, just incompetently. It is certain members of EASA that have shown themselves (repeatedly) to be devious and untrustworthy.

Johnm

12th Nov 2011, 09:12

The restricted privileges IR seems to me to be an ideal solution as it reflects the UK reality that IMCR holder can do anything an IR holder can do except fly IFR in Class A, B or C. If the restrictions are stated in those terms and the UK limit conveniently forgotten, then the Class E airways and class D airports of Europe would be available too :E

englishal

12th Nov 2011, 16:24

That's because the new French IR is not an EASA FCL qualification, just as the IMCr isn't. They won't be valid under EASA FCL and will need a conversion deal also. The UK could also pull such an IR out of thin air too, at present, because EASA FCL is still not in force and won't be until next spring with the variations transition periods following.
That was my point, why didn't the CAA just say "the IMCr is staying, don't worry" rather than all this chit chat which has been going around. I am sure the French IR is here to stay...

Whopity

12th Nov 2011, 17:10

I think that your argument is entirely misguidedTimothy, I hope you are right, but the material I quoted is copied directly from the NPA. Is it going to change that much in the consultation process? No matter what the CAA say or think it will have little effect on EASA. The best opportunity has been missed by the failure of the FCL 008 group to recognise and promote the IMC rating. No doubt its members had other agendas. I don't doubt that there will be some provision to grandfather it however; as nobody in Europe seems to have any knowledge of this rating and its long term effectiveness in achieving a good safety record, I can't see them continuing to let PPL FEs examine for it, neither can I see IREs accepting a standard lower than for the IR.

Genghis the Engineer

12th Nov 2011, 17:11

One subtle difference - the French IR "lite" will be so far as I understand it, ICAO compliant - so useable worldwide, whilst the IMCR isn't and won't be.

Individual states have the right to do their own ICAO compliant things and because it's ICAO compliant allow it to be used worldwide.

There are a lot of examples of this - for example the UK has BCAR 31 which is an ICAO compliant code for large public transport hot air balloons.

G

IO540

12th Nov 2011, 17:24

The French IR is a curious thing.

On the face of it it "has" to end when EASA FCL comes along.

But there is no way the French were going to set this up, with all the supporting infrastructure, only to terminate it in April 2012.

They obviously plan to carry on with it.

And if you look at today's EU power balance, in the wake of the Greek de facto default and the Italian near-meltdown, - it is basically Germany and France calling the shots. Germany is not going to tell France to not do something, and nobody else counts anyway.

The UK, OTOH, has a very long history of being very honourable and following the letter of every treaty they sign... well in the last few decades, anyway ;)

The political climate in the EU is changing, despite EASA clinging onto its gravy trains, but the UK doesn't have the balls to take advantage of it. They could do so, in today's climate, but they won't.

Or maybe the CAA has plans but are keeping their powder dry, which is what I would do ;)

We live in interesting times, not just in aviation :)

FREDAcheck

12th Nov 2011, 18:03

The political climate in the EU is changing, despite EASA clinging onto its gravy trains, but the UK doesn't have the balls to take advantage of it. They could do so, in today's climate, but they won't.
I'm not sure they could. I don't think the UK has as much clout as it used to. The EU is dominated by the Euro area, and the UK seen increasingly as a fringe member, not just in financial matters. When I was first involved in Commission activities (twenty plus years ago) the UK was a required presence in decision making, along with France and Germany (however much the UK sometimes annoyed other countries with a more Atlanticist style). Not now.
Or maybe the CAA has plans but are keeping their powder dry, which is what I would do
What for?

David Roberts

12th Nov 2011, 18:59

Some of us, including a few on this forum, took the trouble to attend (a) the EASA workshop in Cologne on NPA 2011-16 on 30th September and (b) a CAA workshop on NPA 2011-16 on 9 November.

It is clear to me that both the CAA and EASA want to find a solution for grandfathering the IMCR for UK pilots of EASA aircraft beyond the date when the final EU IR becomes effective - which in practice will not be until at least 2013 probably. In my view, since the new IR (and EIR) will not be in place by the implementation date of Part FCL (8 April 2012 - but deferred effectively in the UK until 1 July 2012 and beyond for transition periods) pilots have to be able to continue using existing national instrument ratings (including JAR IR) until the new rules are in place. This should include the IMCR for UK airspace only. Any other scenario would be daft, as it would be regulatory gap which I highlighted to EASA some 4 years ago when pressing for what became the FCL.008 working group task.

There are often many uninformed critics on this forum - and other forums - who still persist in accusing the members of FCL.008 of 'missing an opportunity'. That is frankly not correct (I am being very polite), as has been explained several times by those in the know. The IMCR was NEVER a candidate for transposition to an EU IMCR, period. However good a rating it is.

What is crucial now - apart from getting the IMCR grandfathered - is to support the NPA 2011-16 proposals which are a major step forward for non commercial aviation. If we do not register our support through the CRT process on the EASA website, be sure that there will be plenty of 'other interested parties' who may want to kill off the proposals. On a pure numbers count they could win due to the consultation process and protocols EASA is bound by. You may of course wish to make some suggestions for improvement of the proposals for the IR and EIR, but whatever, support them in general. This opportunity for a change to the JAR IR will not come again for many years.

IO540

12th Nov 2011, 21:51

There is no doubt David that you are right and the FCL-008 IR should be supported.

Taken in isolation, it is the first time in anybody's living memory that the IR gold plating has been rolled back in any way at all.

However, EASA would have had a very easy ride on it had they not first shafted, with a totally arrogantly and politically motivated decree which does not even bother to pretend to be in the name of safety, the FAA IR community, forcing it (on current proposals, anyway) to do an IR conversion course of some sort.

For a converting pilot, the existing ICAO IR to JAA IR conversion is a pretty significant amount of work, and doing the FCL-008 IR is not going to be much less work than that, by the time factors such as exam question bank availability, and the need to do training to meet the flight test requirements are taken into account. I am halfway through the latter and it is basically 1960s type of flying.

My only comments were on the EIR and they were that the ban on STARs will place VFR traffic where ATC simply don't want it, etc. I suppose, however, that a workaround will be to file a DCT from there, to some convenient waypoint. That will work in countries where DCTs are allowed by Eurocontrol.

BEagle

13th Nov 2011, 07:54

Re. the NPA:

1. The sailplane cloud rating will suit sailplane pilots; however, it must be carefully worded to avoid inappropriate use by TMGs using it as a 'poor man's IR'. The other problem is that is doesn't cater for tug pilots needing to operate close to cloud; under present proposals they would need to hold an EIR, which is clearly disproportionate.

2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous. Theoretical knowledge examinations for 'Third country' IR conversions are not mandated in the NPA: it proposes merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment of an experienced FAA IR holder by observing the applicant's pre-flight planning as well as the practical in-flight conduct of the C-B IR Skill Test, perhaps with a few oral questions where necessary. Which, incidentally, is the way I used to assess pilots when I was conducting IR tests on the VC10 in the RAF.

3. The EIR will require diligent pre-flight planning and a Z-type FPL which includes VFR-to-IFR and IFR-to-VFR transition points in the Route section. It will also require a good standard of radio work. Correctly used within its privileges, there is no reason to doubt that the EIR can be used safely. Particularly as a stepping-stone towards the C-B IR.

4. NPA 2011-16 does not include provisions for the national needs of several Member States, including the UK whose IMCR is not provided for - and that is something we cannot accept. So a meeting was held at Gatwick on 9 Nov at which a formal proposal was handed to the CAA. The aim being to secure a solution which will satisfy the national needs of all Member States - and which would greatly simplify the UK CAA's workload in several areas. The UK CAA also stated that, contrary to rumours rife amongst certain parts of the GA community, they would NOT be abandoning efforts to find a solution to the UK IMCR - so if you hear silly rumours such as "Oh well, the CAA will palm us off with the EIR and won't bother with the IMCR", please tell the rumour monger to STFU, because it simply isn't true!

IO540

13th Nov 2011, 08:14

2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous. There were a number of superfluous areas left in there, which I commented on (like the one asking where you would find "Flight Level Zero" - what kind of a trick Q is that?) but I think the wider issue there is that the proposed reduction in the TK syllabus makes this proposal extremely vulnerable as a whole. You only need to post some comment in the prof pilots' forum here about some of the utterly bogus JAA IR TK stuff and see the vigorous comments defending the TK. These people are going to lobby hard to re-instate the old TK. This is why I decided to do the JAA IR now.

'Third country' IR conversions do not mandate theoretical knowledge examinations in the NPA, merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment from the pre-flight planning and in-flight conduct of the C-B IR Skill Test.The words "demonstrate knowledge" have been in the regs for far more years than I would know about, and it has always meant sitting the exams.

So unless you know "something" is in the cooking, I would not expect this to change.

I agree 100% than an FAA-style oral exam would be wonderful because basically any experienced IFR pilot would pass it straight off. But an oral exam (instead of writtens) would terrify most of those passing through the fATPL factory - because they have virtually no flying experience, never mind any IFR experience, by the time they sit their 14 exams. And there are big commercial interests (the FTOs) riding on that. I realise that the CBM IR TK is going to be a different process to the ATPL TK, but that in turn gives ammunition to those against the CBM IR by claiming that the holders of the latter have done a "lesser" IR. Such an assertion would be bogus (because some 90% of the JAA ATPL TK is a load of bollox irrelevant to any form of aviation) but that belief will be held by all of the FTO establishment and nearly all of the transport pilot population :) Which is why I am doing the JAA IR now. I think the CBM IR is a great proposal but I think it is politically very vulnerable.

bookworm

13th Nov 2011, 10:36

The words "demonstrate knowledge" have been in the regs for far more years than I would know about, and it has always meant sitting the exams.

FCL.725 (b) Theoretical knowledge examination. The applicant for a class or type rating shall pass a theoretical knowledge examination organised by the approved training organisation to demonstrate the level of theoretical knowledge required for the safe operation of the applicable aircraft class or type.

(1) For multi-pilot aircraft, the theoretical knowledge examination shall be written and
comprise at least 100 multi-choice questions distributed appropriately across the
main subjects of the syllabus.

(2) For single-pilot multi-engine aircraft, the theoretical knowledge examination shall be
written and the number of multi-choice questions shall depend on the complexity of
the aircraft.

(3) For single-engine aircraft, the theoretical knowledge examination shall be conducted
verbally by the examiner during the skill test, to determine whether or not a
satisfactory level of knowledge has been achieved.

FlyingStone

13th Nov 2011, 11:02

FCL.725 (b) Theoretical knowledge examination. The applicant for a class or type rating shall pass a theoretical knowledge examination organised by the approved training organisation to demonstrate the level of theoretical knowledge required for the safe operation of the applicable aircraft class or type.

Last time I checked IR is neither class nor type rating - I could be wrong though.

englishal

13th Nov 2011, 14:15

My opinion is that the Examiner can make sufficient assessment of an experienced FAA IR holder by observing the applicant's pre-flight planning as well as the practical in-flight conduct of the C-B IR Skill Test, perhaps with a few oral questions where necessary. Which, incidentally, is the way I used to assess pilots when I was conducting IR tests on the VC10 in the RAF.
Surely for a 3rd country IR, the fact that the applicant has already passed both theoretical and oral as well as flight test for the 3rd country IR should be considered sufficient "theoretical knowledge".....as it is now for the IMC rating. (EDIT: I have just re-read what you said and that is exactly what you said ;))...

The oral and flight test should be sufficient for the examiner to accurately gauge the person.

IO540

13th Nov 2011, 14:20

Yes but then you will be doing an "FAA IR" and you can't do that because "we are Europeans and we need European solutions" (the words of one prominent EASA official).

GeeWhizz

13th Nov 2011, 17:25

So a meeting was held at Gatwick on 9 Nov at which a formal proposal was handed to the CAA. The aim being to secure a solution which will satisfy the national needs of all Member States - and which would greatly simplify the UK CAA's workload in several areas. The UK CAA also stated that, contrary to rumours rife amongst certain parts of the GA community, they would NOT be abandoning efforts to find a solution to the UK IMCR - so if you hear silly rumours such as "Oh well, the CAA will palm us off with the EIR and won't bother with the IMCR", please tell the rumour monger to STFU, because it simply isn't true!

What formal proposal is this? What was contained within it? What potential solutions are being considered? Which areas will the CAAs workload be reduced? Where has the CAA stated they will not abandon IMCRs?

These are just a few questions that someone at the CAA should be answering for the GA crew. And refers directly to previous pleas for information. I'm not suggesting that these questions aren't be answered, merely that the answers are kept under lock and key. Answers that should be made freely available to prevent the rumour mill from grinding.

bookworm

13th Nov 2011, 17:36

Last time I checked IR is neither class nor type rating - I could be wrong though.

You're correct. The point I should have made more clearly is that this is a precedent within Part-FCL for the word "demonstrate" to mean a verbal test by the examiner, not a theory exam.

BillieBob

13th Nov 2011, 19:45

Answers that should be made freely available to prevent the rumour mill from grinding.Forgive me, but I don't see why the CAA should be in the least concerned about whether the rumour mill is grinding or not.

GeeWhizz

13th Nov 2011, 19:52

BillieBob you're absolutely correct. But I'm not sure keeping quiet on these topics is a great way to keep GA pilots with their hard earned ratings, on side.

IO540

13th Nov 2011, 20:23

To be fair to the CAA, they are right to keep silent on this intensely political stuff.

France has the advantage of being French i.e. they are very polite in the open and when the door closes they stick their middle finger up and do as they please. This is an effective way of dealing with the crooked gravy train riders who are in charge of the EU, but the UK CAA doesn't have the balls to do stuff which is quite so crude.

I am sure a way will be found to preserve the IMCR, but you won't hear about it till the last minute. So much s**t has hit the fan over the EASA proposals to shaft IMCR and FAA IR holders that EASA had to do under the table deals with MEPs to get enough votes, and the under the table stuff would have been assurances that such and such will be solved amicably.

BEagle

13th Nov 2011, 21:44

GeeWhizz, those of us representing AOPA, BGA, EAS, LAA and PPL/IR who are working with the CAA to try to find a way to retain the UK IMCR for the future are NOT going to publicise each and every stage of our deliberations in case we run into regulatory brick walls and have to resort to different tactics.

You will just have to trust us. Sorry, but that's the way it is. There are enough stupid rumours doing the rounds and I am NOT going to give the opportunity to some village idiot to spin his own incorrect intepretation of matters which are somewhat sub rosa.

GeeWhizz

14th Nov 2011, 00:52

In BEagle we trust! :p

IO540

14th Nov 2011, 06:51

There is a fine video showing Seebohm (an EU official who likes his lunches) saying (paraphrasing) that there are areas in aviation where there is no regulation, and therefore they need to create some.

Timothy

14th Nov 2011, 14:40

In BEagle we trust! :p
I have to tell you that BEagle is doing a bloody good job (backed up by an array of well informed helpers.)

Both AOPA and PPL/IR will be putting in reasoned responses to the NPA. It is great to be able to report that the two organisations are working closely together, and are very much on the same page. This is not a time for there to be any division in the ranks of those representing PPLs, and there is none.

You are going to have to trust us, to a large extent. That is what we are for, and why you pay us your subs.

If this goes well, this will be the greatest advance in PPL licencing in the 40 years since I have been flying, certainly since the IMCR, and we hope to demonstrate to you that membership of organisations like AOPA and PPL/IR really pays off in these once-in-a-generation times.

SDB73

14th Nov 2011, 16:30

Is there not a whole hill of "guilty until proven innocent" going on here?

I think it's important to voice opinion of how things should be. But blanket calling people self-serving scum even before they've actually presented the final regulations is a bit strong.

As a UK PPL/IMCr, who flies a G reg, I have to say I'm all-for the current LIKELY changes, and feel pretty strongly that enough importance is being placed on allow me to continue to use my privs, and probably give me a sensible route to far MORE privileges.

I can understand FAA/IR's getting upset to a degree, but in SOME ways - being brutally harsh - the whol FAA/IR/N-reg thing has always been a LITTLE BIT of a "loop hole" rather than the way it was always supposed to be.

In motorsport we often use the term "The spirit of the regulations", and as soon as you try to use the letter of the regs to your advantage, knowing that it wasn't what was originally intended, it's always a short lived benefit. I know this doesn't 100% apply here, but it's close.

Either way, who don't we just show ourselves to be gentelemen and offer solutions.. I know that if I were in charge I'd respond way more favourably to that, than to being called a crook!

BEagle

14th Nov 2011, 19:02

No thank you, Silvaire1. The next thing would be talking about 'aloominum' or saying "Have a nice day" to everyone.....:(

Timothy, thank you for your kind words! The main frustration at the moment is having to cope with unqualified comments from those who simply haven't bothered to understand what's on offer.....

Johnm

14th Nov 2011, 19:41

Very well, suffer on in ineffective and confining isolation - it is a European specialty.

EErrr excuse me how do you think half the planet's population ended up speaking English and most of South America Spanish and Portuguese. Where was the first digital computer developed, where was the first steam engine built, who developed the automobile and first flew (no it wasn't the Wright brothers in the US, they were Johnny come Latelies) where was gravity discovered the telescope invented........ :ugh:

Johnm

14th Nov 2011, 20:14

Silvaire I don't think we'd disagree about the European Commission and its institutions, happily there's still plenty of European activity that isn't controlled by the commission, through aviation isn't one of those sadly.

BillieBob

14th Nov 2011, 20:40

happily there's still plenty of European activity that isn't controlled by the commissionGive it time, my boy, give it time.

cockney steve

14th Nov 2011, 21:01

I'm all for the "septic's" regulatory system, if it means we can adopt their "experimental" and "sports / light aircraft " categories.

OK, so single-seat microlights are now released from a lot of the onerous red-tape compliance -issues, but there's no cheap way to fly rotary in the UK..... OK, For the pedants, the possibility of lower-cost rotary -flight is denied us, as are many of the innovative delights of the USA.

Sorry for the thread-drift,- but their liberal attitude also appears to apply to their other legislative areas.......if you want to risk your own neck, it appears that they'll let you.

IMCR appears to be a pragmatic solution to those to whom the cost/time of obtaining a full IR is prohibitive,yet need a legal method of flying in weather defined as IMC.

The"hobby" of GA seems to be grossly over -regulated in the UK,perhaps that's why it remains an elitist ,minority activity.

Timothy

15th Nov 2011, 16:54

it is a European specialty
I think you'll find that it's speciality :p;)

FREDAcheck

15th Nov 2011, 17:00

I think you'll find that it's speciality
A pedant after my own heart!

We're a dying breed.

Timothy

15th Nov 2011, 17:07

...not a pedant, just highlighting another transatlantic difference.

Fuji Abound

15th Nov 2011, 22:05

BEagle

Timothy, thank you for your kind words! The main frustration at the moment is having to cope with unqualified comments from those who simply haven't bothered to understand what's on offer.....

Forgive me, but that is a little harsh. It is the job of the regulator and our representative bodies to inform, as much as the individual to be informed.

The law making process to be effective should be consultative and if if is not dont expect the law to be necessarily effective or supported.

I am not convinced that the rank and file have much idea what is going on even if they have made considerable effort to be informed. That is more the fault of the messengers than the recipients. Worse still the mesengers seem to be unclear themselves or as equally caught up in smoke screens, politics and subterfuge;). Dont be entirely surprised if the great unwashed are reduced to speculation, gossip or willful mischief making. Even aopa for some while seemed uncertain which horse to back and why, lest we forget.

Clear and concise statements of what is on the table, why and who supports what is still in very short supply - a transparent process it is not.

soay

16th Nov 2011, 07:34

caught up in smoke screens, politics and subdifuse
More pedantry: I wonder if any spell checker can figure out that subdifuse probably means subterfuge? ;)

Timothy

16th Nov 2011, 10:04

While (whilst?) using this site, I'm particularly amused by the spell checker correcting whatever UK spelling I might use into US spelling.
My guess is that the spellcheck will be coming from your browser, not PPRuNe, so the settings are at your control.

I use Chrome (the best of all browsers at the moment) and you right click an underlined word, choose spell-checker options, and you can select your language.

proudprivate

16th Nov 2011, 12:13

can understand FAA/IR's getting upset to a degree

I assume you mean "up to a degree, I understand FAA/IR's getting upset".

The degree to which the FAA/IR's themselves are upset varies according to the following parameters :

- having been the recepient of disingenuous communications both orally and in writing by reasonably to extremely generously paid European civil servants and politicians

- having invested a non-negligeable amount of time and money in flight training and currency experience which threatens to be become invalid or very cumbersome to convert

- having witnessed first hand a regulatory process devoid of democratic control, transparency or proper statistical or scientific motivation

- having been the victim of discrimination

In motorsport we often use the term "The spirit of the regulations", and as soon as you try to use the letter of the regs to your advantage, knowing that it wasn't what was originally intended, it's always a short lived benefit. I know this doesn't 100% apply here, but it's close.

Being a PPL for less than 1 year, I don't think you grasp the situation here. I also think you are unaware of either the history, the spirit or the letter of the regulations. If you were, you would probably be more upset.

In transport, as opposed to motorsport, we don't often use the term "the spirit of the regulations", because regulations in the transport sector infer a direct cost. That is why it is imperative that any regulation has a properly balanced and motivated safety reason behind it.

Imagine the following regulation, not entirely dissimilar to the situation we experience now :
"UK drivers who wish to use their motor vehicle on the continent should sit an exam to assess their capabilities of driving on the right hand side of the road as well as their knowledge of traffic regulation differences between the UK and France, Germany and Italy".

421C

16th Nov 2011, 12:34

Clear and concise statements of what is on the table, why and who supports what is still in very short supply - a transparent process it is not

What exactly is the transparency you are looking for?
At this point David Robert's and Beagle's posts have summarised what is on the table (ie. NPA2011-16, including the proposed IMCR grandfathering) and the position of UK stakeholders that, additionally, the UK would like to see a continuation of the IMCR rather than just grandfathering.

Precisely how the UK authorities will pursue the latter is not something, I guess, they are going to detail for it to be published on PPRUNE, in the same way that most of the negotiation and horse-trading that goes on in the world isn't made transparent on internet forums.

The other obvious transparency on "why and who supports what" is through the CRT process - all the responses end up in the public domain, so you will be able to see exactly who supported what and why in hundreds of pages of minute detail. At present I think all the representative bodies are drafting their CRT comments. If you are a member of one of the GA representative organisations, then I imagine there are channels whereby you can input your views in the drafting process.

brgds
421C

Fuji Abound

16th Nov 2011, 15:10

421C - as you have said the process is not transparent, so you didnt really need to ask the question of me. Whether as much as any political process is transparent is another debate; we all know the reality is that it isnt.

Whether AOPA, the CAA, EASA and other commentators have manged to give the best possible, clear and concise advice on what is or isnt likely to happen is much more debatable. If you had been involved in the process since the start (and perhaps you have) the conflicting reports that have been published, the changes of stance and the political posturing have been a truly disappointing reflection on the whole process.

National qualifications have been with us for ever; how these were to be accomodated in the process could have been set out very much earlier on, and in this much the Regulators have failed us all.

421C

16th Nov 2011, 18:19

National qualifications have been with us for ever; how these were to be accomodated in the process could have been set out very much earlier on, and in this much the Regulators have failed us all
No, it was set out very clearly right at the start of the process. The same 2008 EU law that gave EASA power over FCL made it clear there would be NO accomodation for national qualifications that did not become EASA FCL qualifications.

Whether AOPA, the CAA, EASA and other commentators have manged to give the best possible, clear and concise advice on what is or isnt likely to happen is much more debatable.
I think broadly the position people have taken for a long while has been
- IMCR grandfathering: possible
- IMCR continues as a UK qualification: unlikely
- IMCR adopted as an EASA qualification: utterly unlikely
No-one has been able to give clearer answers because no one has had clearer answers.

as you have said the process is not transparent, so you didnt really need to ask the question of me. Whether as much as any political process is transparent is another debate; we all know the reality is that it isnt. No process is totally transparent. Firstly, because some processes are unstructured and managed situationally. No-one can give you "transparency" on how the euro crisis is going to be solved, because no-one knows. Secondly, some elements of a process are going to be private. If you disagree, you are welcome to join Julian Assagne in a campaign to end privacy in anything. But some UK stakeholder is going to go to Brussels to negotiate stuff with EU peers without telling you on PPRUNE in advance what their negotiating position and strategy is.

As I said, I think there has been reasonable transparency to date and where commentators have conflicted it's because no-one knew the answers. The transparent EASA FCL-NPA-CRT-CRD-Comitology process has given it's answer - no IMCr, other than grandfathering. If you want to pursue the cause through a transparent process, then that process is the EU legislative one - getting the law changed. Otherwise, there is an opaque process of cutting a deal somewhere that no-one can tell you much about. Personally, I wouldn't give it better than a 20% of working, but then I am probably wrong because I know no more than you do.

brgds
421C

Fuji Abound

16th Nov 2011, 21:32

The same 2008 EU law that gave EASA power over FCL made it clear there would be NO accomodation for national qualifications that did not become EASA FCL qualifications.

Exactly. A complete absence of clarity on which national qualifications would and wouldn’t be embraced by EASA.

I think broadly the position people have taken for a long while has been
- IMCR grandfathering: possible
- IMCR continues as a UK qualification: unlikely
- IMCR adopted as an EASA qualification: utterly unlikely
No-one has been able to give clearer answers because no one has had clearer answers.

You only re-enforce my point because you confuse the debate with a very different process:
No-one can give you "transparency" on how the euro crisis is going to be solved, because no-one knows.

No one knows the out come of the Euro crisis because it is not a regulatory process. A regulatory process is artificial and controlled by its perpetrators. A regulatory process is born from a perceived need to pass legislation to address a problem (in this case the need for uniformity in aviation regulation throughout the Community). The process should comprise consultation, to establish how the legislation should be framed to address the problem, proposing legislation, further consultation to identify any deficiencies in the proposal, and enacting. Broadly this is precisely what has taken place. Unfortunately the consultation was poisoned by national interests, stakeholder self interest, international politics and an agenda which was known to be unpopular and therefore was covert.

None of these elements have any place in the safe conduct of aviation.

You and I have had similar debates before. I always enjoy our debates and you always put your arguments eloquently. In some respects however you and I live in very different worlds. I fully understand why some never wanted the process to be clear and I fully understand that is often the way of politics. Never the less that neither makes it right, nor does it ensure a desirable outcome.

In the case of aviation, and in particular General Aviation, the population is so transient and the representation so ineffective that there are few of us already that remember when this debate started let alone will be around at the end of it. Of those, few have the desire or energy to do anything about it. For those reasons the “Regulator” may get away with murder, but it says something when the Commission overseeing the whole process has had to take EASA aside on a number of occasions already and read them their fortune.

No, the process was poisoned from the start, bereft of clarity (albeit I would concede possibly by intention) and in consequence has become bogged down in one delay after another, statement, retraction and eventually silence, so in as much as you and I agree you are quite safe in your earlier comment that “no one has any clear answers”.

It is a farce, you know it, I know it, and this forum leaves us in very little doubt.

Will any good come of it? Well I am an optimist – I think we are getting there, but my goodness it is model if you repeated in industry would be a sure certain way of quickly ending up in the London Gazette listings.

In so far as it has any similarity with the Euro crisis it does in this much - a Europe which is bereft of the political will to face up to its United responsibilites because the politicians cant escape their national interests.

thing

16th Nov 2011, 21:43

Without having to plod through pages of I'm sure worthy text none of which I understand because I just fly for pleasure and have no interest in Euro stuff other than it would be a good idea to shoot a few of them at random now and again just to keep them on their toes, what is happening to the IMCR? There are three possible answers:-

1. No one knows.

2. It will be grandfathered/you can still use it in the UK as per normal.

3. It will be scrapped and the money I'm spending now will be wasted other than the extra flight training in precise flying it will give me.

The rules are that you can't give any answer other than the three options above. Don't be afraid to say no one knows, your standing will not shrink because of it.

IO540

16th Nov 2011, 21:56

In the case of aviation, and in particular General Aviation, the population is so transient and the representation so ineffective that there are few of us already that remember when this debate started let alone will be around at the end of it. Of those, few have the desire or energy to do anything about it. For those reasons the “Regulator” may get away with murderThat's a brilliant summary.

In any regulatory activity, the unelected incumbents will always run circles around elected politicians, and it's doubly bad in GA because the vast majority of the players are just passing through.

But on this occassion I think it is not worth worrying about it. I really do think the IMCR will survive in some form.

Anybody comtemplating the IMCR should just get on with it anyway because "VFR" capability is vastly enhanced by instrument skills ;) Even taking the normal legal stuff, like flying in 3000m vis, requires radio nav. So do other things e.g. night flight, flying over the sea into the sun, etc. IMHO, every pilot should be able to make a seamless transition from visual flight to instrument flight, as necessary. Every flight should be planned and executed as IFR, with visual conditions being regarded as a bonus. Much safer.

Fuji Abound

16th Nov 2011, 21:57

Thing, I am not sure whether you are asking a question or making a statement?

For fun I am going to assume you are asking a question and give you an answer,

1. There are those that think they know, there are those that dont know but would like you and I to think they do, there are those that might know but arent going to tell you and I, and there are those that are still trying to change what they think they know will happen.

2. Who knows, but most people who think they know, think it will.

3. There are those that are happy to see you spend your money and would be even more happy for it to be wasted but no one knows or if they do they arent saying whether those that are happy to see you waste your money know or whether the current concensus is correct that those who arent saying but believe there will be grand father rights know.

Is that clear?

Fuji Abound

16th Nov 2011, 22:00

That's a brilliant summary.

Thank you.

and so are you further comments. ;)

thing

16th Nov 2011, 22:08

Fuji Abound

16th Nov 2011, 22:22

I like yours as well, Sir! ;)

so need concise replies from those who understand these things

now that is were my friend 421C claims he is able to help us all. ;)

Here is EASAs reply to your said same questions:

1. Maybe,
2. You will have to ask the French,
3. Dont worry you definitely havent wasted your money, we know in EASA how to put all money spent in the pursuit of aviating to a very good use - in that much we want to be absolutely clear, until you ask us to account for how we have spent your money, in which event you will have to ask someone else, but we want to assure you it has been well spent. Of that much we are certain. In fact come to think about it, it is the only thing we are certain about at the moment. Otherewise, we refer you to answer 1 above.

thing

16th Nov 2011, 22:27

Can't we just bomb them? Make it look like an accident? We have plenty of combat qualified guys in the RAF. I reckon we would get away with it. There may be repercussions, questions asked in the house, some senior heads roll etc. But I reckon it might be game on if we could get some support.

Fuji Abound

16th Nov 2011, 22:36

PS I was just thinking about the CAAs response to the question - what is going to happen to the IMCr.

Apparently, they say this is still to be decided - is that the same as saying no one knows? Certainly it would seem they dont know, or if they do, they arent saying.

So the trouble with bombing the lot of them is that it would seem none of us know whether we will be blowing up something that is "good" or something that is "bad".

I am calling it a night, left only with the thought that you couldnt make it up if you tried - reality is a whole lot scarier than make believe.

proudprivate

17th Nov 2011, 09:49

Can't we just bomb them?

We have given this ample thought already. My own idea was to buy a second hand SU-27 and fly the missed approach at Cologne-Bonn, which should put us close enough to the river to finish the job.

Others have suggested to put the British aviation heritage to good use by deploying xh558, but then using better droppings than they had at Stanley.

Make it look like an accident?

It's possible, but it would be tricky for an RAF pilot to explain. The Luftwaffe also does most of their training in the US. USAF action is hairy too, as it might be misinterpreted in the context of the Bilateral Safety Agreement negotiations. Best is probably to engage some friends at Kleine Brogel. They've done it before.

So the trouble with bombing the lot of them is that it would seem none of us know whether we will be blowing up something that is "good" or something that is "bad".

To quote David Roberts, "I wouldn't worry too much about that"

;)

Timothy

17th Nov 2011, 10:13

If you guys stepped back for a minute and looked at the effort and resources the CAA (and NATS and RAF) are throwing at keeping recreational aviation flying during the Olympics, you would be a little less rude and dismissive about their efforts to retain the IMCR, in the best available form within the law.

Equally, there are many people at EASA (not all of them, I concede) who are trying to find the best solution to satisfy as many people as possible.

By all means slag off the experiment to make Europe one superstate; by all means criticise the Commission and the European Parliament for being self-serving and politically motivated, but please remember that the CAA for certain, and many elements of EASA are working their socks off to make this change as low impact as possible.

So let us not just slag them off, especially if we, by our own admission, cannot be bothered to find out what's really going on.

FREDAcheck

17th Nov 2011, 10:37

By all means slag off the experiment to make Europe one superstate; by all means criticise the Commission and the European Parliament for being self-serving and politically motivated
Thanks, I probably will :)
but please remember that the CAA for certain, and many elements of EASA are working their socks off to make this change as low impact as possible
I dare say that's true, but we don't get to hear much about that. Lots of talk about things having to be done behind closed doors, can't tell you too much but trust us...

Yes, I do understand that, but in an open society we positively don't trust anything that goes on behind closed doors, and nor should we. However hard people are working for us, when things are not exposed to the harshest light of public scrutiny (even for good reasons) they must expect skepticism and at times criticism, even if unjustified. Goes with the territory.

Fuji Abound

17th Nov 2011, 10:49

Timothy - I think you got out of bed the wrong side this morning. I dont see anyone suggesting the CAA arent working hard on these issues (well not in any of the recent posts or my posts in particular), albeit it has to be said we only have your assurance and the assurance of a few others on which to base that conclusion. If I were a cynic they could well be feeding you what they want and you could be gullible enough to believe it - not that I am seriously suggesting that is the case. ;)

Frankly I get fed up with comments along the lines "dont worry, we are working hard in your best interests"! Let it not be forgotten that the job of any Regulator is to be transparent, to inform and to respect their committment to those they serve. However hard these people are working it is quite clear to me that they have not been transparent and the process has been to date poorly managed. If you wanted any more convincing evidence I cant imagine the Commission would have read EASA their fortune unless there was a reasonably compelling reason for doing so.

As to your frequent comments about people being bothered (or not) with regards to finding out what is taking place thing in his earlier post was spot on so far as I am concerned - and so I need concise replies from those that understand these things. I see no good reason why the average pilot should be bothered any more than the average taxpayer shoudl read through 75,000 pages of tax legislation that is published every year.

With regards the IMCr and the CAA as I said earlier their reply is certianly concise after nearly three years of this process - the CAA doesnt know. ;) Well if they dont know, I guess no one knows. Worringly one suspects they do know, or have a jolly good idea - but they are not saying. That would be reasonable at the start of this process, it would be reasonable after a year of consultation, it might be reasonable after two years of consultation but it is no longer reasonable.

By any test the process is not a model of open governance.

As I said earlier I am an optomist; I hope and believe a reasonable outcome will be reached. I also believe there are some good people working to protect the interests of GA. I hope I am right.

With respect I think your post is out of touch with everything I read and in almost every discussion I have with other pilots which is a worry. What you and I think about eveyone joining AOPA and pooring over every utterance of EASA and CAA may all be very well, but it is not going to happen. People will not join AOPA because they are told they should, and they are not going to read the legislation when they have barely got enought time to deal with everything else life throws at them. Life just aint like that, unless you are part of the ranks of us sad lot that get some weird satisfaction from a good debate! :)

proudprivate

17th Nov 2011, 12:25

especially if we, by our own admission, cannot be bothered to find out what's really going on

Excuse me ? Cannot be bothered to find out what is going on ?

Some of my friends and I have from way back worked our socks off, voluntarily, to find out what was going on, by placing phone calls, writing letters, requesting information and what not, usually either to be stonewalled by some overpaid legal pond scum or to be lied to in our face.

Equally, there are many people at EASA (not all of them, I concede) who are trying to find the best solution to satisfy as many people as possible...[and] to make this change as low impact as possible.

We can only hope for reason to prevail and as low an impact as possible.

Failing that and a failing a proper dialogue, the only other thing a citizen or an organisation can do is take a few institutions to court. As far as I can tell, the European Commission does not benefit from "Crown Immunity".

Timothy

17th Nov 2011, 12:32

A group of us were asked the other day whether we thought that people who made outrageous threats on internet fora were a real threat that needed to be considered a risk (this was in the context of Olympic security planning.)

The general consensus was that those who made the most online threats were probably the ones least to worry about.

Any of you who really wants to know what's going on can join the effort of the representative organisations. I personally can speak only for PPL/IR and AOPA, but both organisations suffer from too little member involvement, not too much.

You can attend AOPA Members Working Groups and you can observe the PPL/IR Executive Committee. You can then volunteer to attend meetings with EASA, CAA and NATS and ask all the questions you like.

Or you can sit at home on a forum and threaten to sue.

Your call.

Fuji Abound

17th Nov 2011, 12:58

Timothy - I thought we were in for a little debate, but then you spin the usual party line.

By all means go on encouraging people to join AOPA, PPL/IR etc and remind everyone what a good job they are doing. I have no doubt they contribute to the process with varying degrees of success.

The fact remains that less than 10% of the GA population sees fit to join - if I were selling something, it would rather make me look at how I was going about it, than having a go at the punters.

Still, I have no doubt AOPA et al think they know best.

History on the other hand would suggest it is actually their call to make.

Thee is an old saying about waking up and smelling the coffee but it is difficult when you head is beneath ten feet of sand.

proudprivate

17th Nov 2011, 13:00

Any of you who really wants to know what's going on can join the effort of the representative organisations. I personally can speak only for PPL/IR and AOPA, but both organisations suffer from too little member involvement, not too much.

I happen to have personal issues with PPL/IR and with IAOPA, in particular with respect to their stance towards FAA PPL/IR's at some occasions in the past, which is why I don't join them. That is a purely personal choice and is off-topic here. I'm a contributing member of several other organisations, though.

Or you can sit at home on a forum and threaten to sue.

That is what several people I have spoken to are contemplating at the moment. I don't think they sit at home and I don't think the threat is in vain. That being said, going to court is something you only do as a last resort, because it is costly (around the price of an ab initio PPL-training) and results aren't due for about 12-18 months, more if the Commission or EASA are dragging it (a likely event in a serious court case).

Of course one should comment on NPA 2011-16. As as organisation, preferably, but also as an individual. I would urge everyone that can read or write to register for EASA's CRT application and produce meaningful, productive comments. This includes skimming through a 200+ pages legalese document with a yellow marker and thinking through possible solutions over a cuppa in bed at night. Not my favourite activity, but hey, we have only a few passions in life, and flying is one of them.

That being said, if my experience is anything to go by, my well thought through comments will be studiously ignored, as will those of many even more experienced pilots, flight instructors and examiners, no matter how reasonable and how astutely formulated.

All in all, I think your "black and white" representation of facts and categorizing of people is misplaced at best and I would urge you to introspect on this.

Timothy

17th Nov 2011, 13:10

The fact of the matter is that the representative organisations are invited to EASA and the Belgrano, our opinions canvassed and our representations taken into account. That is a process taking place all the time. The upshot is better regulation based on rational discussion.

At the beginning of the Olympics process, when the Spooks were telling us that whatever we said they would do what they wanted, I started a process towards Judicial Review. DfT (particularly in the form of Theresa Villiers) and CAA jumped in, pushed back against the HO and won the day. Now the discussion is rational.

So we can all make up our own minds. If you think that legal action or the threat of legal action will have a beneficial effect, have a go. When the HO thought that they could get away with draconian force, we had to look to the judiciary. But my view is that while the other side are willing to talk, and CAA and EASA are very open to talk about IR, EIR and IMCR, the best thing to do is to talk.

421C

17th Nov 2011, 13:20

Exactly. A complete absence of clarity on which national qualifications would and wouldn’t be embraced by EASA. I don't understand your strange pursuit of an impossible "clarity". Aren't the normal process steps involved obvious? I will try and spell it out.
First step: the EU passed a law (Basic Regulation) saying EASA would have scope over FCL and all pilot quals in Europe would have to be EASA ones, ie. nothing national.
At this point, no-one had decided what those EASA quals would be. But there was a process to decide:
Second Step: AFTER the Basic Regulation empowered them to do so, EASA set up FCL001, wrote an NPA, got CRT responses, published a CRD, got responses to that, published a Final Opinion, it went through the Comitology Process and became EU Law.
This second process determined, as you say, "which national qualifications would and wouldn’t be embraced by EASA". Your problem is that you want an impossible combination of "clarity" and "transparency". Clarity emerges from a process. If you want transparency, you will see the process workings before answers have emerged - therefore no "clarity" on the answers. If you don't want answers unless they final and definitive, you won't get them until the very end of a process and then will claim no transparency.

No one knows the out come of the Euro crisis because it is not a regulatory process. A regulatory process is artificial and controlled by its perpetrators. A regulatory process is born from a perceived need to pass legislation to address a problem (in this case the need for uniformity in aviation regulation throughout the Community). The process should comprise consultation, to establish how the legislation should be framed to address the problem, proposing legislation, further consultation to identify any deficiencies in the proposal, and enacting. Broadly this is precisely what has taken place No, you are confusing two different processes. Yes, there is a structured regulatory process as you described. It's the one I described involving the BR-FCL NPA-CRT-CRD-Final Opinion-Comitology. The problem is that process worked as it is meant to, but gave an answer you didn't like - no Euro-IMCr. There is no such structured process to resolve secondary issues like grandfathering and national opt-outs/exceptions/flexibility. It is an unstructured negotiation. Hence my analogy with the euro crisis. No-one can give you more "clarity" on either of those two unstructured processes. Let me illustrate. If the UK government reps offered nothing except a thank-you letter in order for the EU to exempt the UK and allow the IMCr to continue, I believe they would be unsuccessful. If they offer $10bn of aid to Greece in return, I believe they would be successful. What exactly the negotiation/discussion will be, what its paramaters and trade-offs and constraints will be I have no idea and I think it's silly to expect "clarity" on this.

Unfortunately the consultation was poisoned by national interests, stakeholder self interest, international politics and an agenda which was known to be unpopular and therefore was covert. I think it's simpler than that. The other EU countries didn't want the IMCr as a Euro rating.

I fully understand why some never wanted the process to be clear and I fully understand that is often the way of politics..............Worringly one suspects they do know, or have a jolly good idea - but they are not saying..............By any test the process is not a model of open governance What exactly do you think is being kept hidden?

"and so I need concise replies from those that understand these things. ....With regards the IMCr and the CAA as I said earlier their reply is certianly concise after nearly three years of this process" So what you are saying is you want a concise reply, but you don't like the reply you got? What are they expected to reply? Until the actual instrument by which the IMCr is grandfathered is enacted, there can be no certainty. Anything can happen at the last minute. So if you want an answer you can depend upon, you have to wait until it is certain. And until it's certain, people will tell you they don't know if they are accountable for answers they give.

I still don't understand what you think, specifically, you are being kept in the dark about?

brgds
421C

proudprivate

17th Nov 2011, 13:31

and CAA and EASA are very open to talk about IR, EIR and IMCR, the best thing to do is to talk.

Agreed. And it is not because some of these people deserve to be shot, that one shouldn't grasp every opportunity to talk, to opine and to negotiate. Or in this case, participate in an NPA.

It is indeed my impression that certain unaccountable government elements can be coerced into a rational discussion when legal action is a real possibility, if only because it can negatively influence their (political) career. I wouldn't put all my cards on it, but I would advise any person affected to gather and maintain a proper documentation trail in case of necessity.

The fact of the matter is that the representative organisations are invited to EASA and the Belgrano, our opinions canvassed and our representations taken into account. That is a process taking place all the time. The upshot is better regulation based on rational discussion.

In theory yes. In practice thus far as regards for example Part-FCL001 Comitology no. I hope you're not representing that FCL001 and NPA 2008-17b was an exponent of better regulation based on rational discussion.

That doesn't mean things can't improve though.

Fuji Abound

17th Nov 2011, 13:53

So what you are saying is you want a concise reply, but you don't like the reply you got?

No, that is as removed from what I said as it is possible to get.

To suggest that my views stem from whether I like the reply or not does you little justice. From the point of view of my own self interest I couldnt careless what happens to the IMCr. I have fought hard for its retention and have set out on many occasions my reasons.

If, as you suggest, the Euro IMCr was never part of the process, then you have demonstrated even more convincingly that the process was flawed. You cant embark on a structured process that ignores elements that must be resolved, and if you didnt realise in the first palce that those elments would need to be addressed or sought to exclude them for political purposes then the process was flawed from the outset.

If you want transparency, you will see the process workings before answers have emerged - therefore no "clarity" on the answers. If you don't want answers unless they final and definitive, you won't get them until the very end of a process and then will claim no transparency.

You are intent on making a very simple process complicated. At the start of the process everyone knew national qualifications existed. EASA saw fit to abolish national qualifications whilst retaining the option to encompass these qualifications within EASA qualifications in some shape or form. At a very early stage it was therefore clear that the future of the IMCr would have to be addressed and more especially thought would need to be given to those who already held national qualifications. EASA had ample opportunity to set out their proposals for addressing this issue - so far as I am aware they failed to do so, and have still failed to do so. Of far greater concern EASA and the CAA have failed to give any indication as to how they propose to address the issue.The debate, whatever the debate, has been shrouded in a cloud of mystery.

It is a truly dreadful state of affairs and reflection of a failed process.

It is time to face the facts or bury your head in the sand.

thing

17th Nov 2011, 14:39

Until the actual instrument by which the IMCr is grandfathered is enacted, there can be no certainty.

I take it that means 'no one knows'.

Timothy, it's not that people aren't interested in AOPA etc, it's just a matter of time as someone has already said. I have a busy life, I'm sure most people here do. There are only 24 hours in a day. You have chosen in your spare trime to become involved in aviation organisations, I do other things in other fields that are worthy pursuits. I don't see anything wrong in asking people who are in these organisations for a concise reply to a question when with the best will in the world I wouldn't have the time to wade through a mountain of legislation.

I certainly don't denigrate the efforts of the CAA either. Our CFI is a 'wheel' there and I know the amount of stuff he has to wade through.

Timothy

17th Nov 2011, 14:58

thing,

All we really ask is for your membership, subs and support.

I was just talking to the armchair warriors when I said that they could become involved if they wish.

BEagle

17th Nov 2011, 16:40

Sitting here in a cheap and rather tacky hotel in the back streets of Köln after a day of listening to €urocracy, I can assure you that things would be considerably worse if organisations such as EAS and IAOPA didn't participate in EASA discussions!

However, EASA needs to understand that it isn't the Commissions special favourite by any means - so when I hear that anyone in EASA isn't taking heed of the Commission's statements, my alarm bells start to ring.

There is an element of 'Befehl ist Befehl' rife amongst some people at EASA which needs to be robustly challenged!

soaringhigh650

17th Nov 2011, 17:51

I personally can speak only for PPL/IR and AOPA, but both organisations suffer from too little member involvement, not too much.

Why not merge these two, Gasco and GA Buyer Europe magazine, who also runs AeroExpo?

The four groups would form a much larger, more influential organization.

Quick! Before one of them die.

Timothy

17th Nov 2011, 18:35

It might work, but there are some minor differences of emphasis between the bodies which could transfer into internal wrangling. It is already difficult enough to ensure consensus.

For example, PPL/IR would probably like universal Mode S, whereas some AOPA members would find that untenable.

We work together - for example AOPA and PPL/IR are sharing much information in the IR NPA, and PPL/IR organise the seminars for Aero Expo.

I see no sign of imminent death for any of them; certainly the ones I am involved in are in rude health and fighting fit.

Fuji Abound

17th Nov 2011, 18:58

Aopa sadly has a history of being unable to work with other organisation so the current arrangements are the best we can hope for.

BEagle

17th Nov 2011, 19:05

I see no sign of imminent death for any of them; certainly the ones I am involved in are in rude health and fighting fit.

There is a clear synergy in working together! Each organisation has its core strengths, but the whole is greater than the sum of the constituent parts.

IO540

17th Nov 2011, 19:20

PPL/IR would probably like universal Mode S

I don't think that is at all true. Mode S has exactly zero value to anybody in light GA, over Mode C.

Even transport jet TCAS gets no benefit from GA targets having S, over C.

Some ATC units in the "white christian" Europe use Mode S to help jet traffic management, and e.g. NATS have some fancy software for holding stack display and management, but light GA doesn't go anywhere near that airspace. Even a PA46 or a Jetprop doesn't go into the same airspace.

Mode S would be worthwhile if one got TIS uplinked over it but that won't happen because nobody is going to pay for it.

What would make sense is mandatory Mode C - on all aircraft technically capable of carrying it. But there are so few midairs that nobody is going to do that one either.

Fuji Abound

17th Nov 2011, 20:10

but the whole is greater than the sum of the constituent parts.

I think therein are words of considerable wisdom.

I don't think that is at all true.

More words of wisdom. I was surprised to see this pedalled and more surprised that the membership of the PPLIR would think any such thing - but who knows.

I have to say that some of the views expressed on this thread by some recently are so far removed from what I am told, understand and believe that I simply cannot recognise them as anything to do with the world I know. It worries me that some people involved with these processes are unable to distinguish between the world the rest of us know and the world in which they clearly exist.

certainly the ones I am involved in are in rude health and fighting fit.

I would hardly call a £30K loss and a similiar fall in membership income rude health, but equally, it is not a bad performance in these difficult times.

Pace

17th Nov 2011, 21:14

I cannot see what the problem is in the CAA retaining the IMCR in the UK?
If the French at the swing of a pen create a French PPL IR why all this hassle over a PPL IMCR in the UK.
All the UK has to do is a lesser move than the French.
" We are creating an existing UK rating called the IMCR! As before it is only useable in the UK and follows what we have always had in place!"

End of story! No Hassle! No Sweat!

Someone is not being straight?

Mind you the way Europe is self disintegrating I dont know what sort of Europe or EASA we will have 2 years down the line if any?

Pace

robin

17th Nov 2011, 21:24

However, EASA needs to understand that it isn't the Commissions special favourite by any means - so when I hear that anyone in EASA isn't taking heed of the Commission's statements, my alarm bells start to ring.

There is an element of 'Befehl ist Befehl' rife amongst some people at EASA which needs to be robustly challenged!

I agree, but there is no sign that the Commission or the EU Parliament is actually challenging EASA in any meaningful way.

We heard a lot of good stuff during the latest FCL debate about how unacceptable EASA's proposals were. But when the crunch came, no-one actually challenged them and the proposals were voted through, even though they are still half-baked.

At one point I wrote complimenting the chairman of the Transport committee for the way they showed how badly EASA operate. I was appalled when he then rolled over and accepted the FCL proposals even thought they are nowhere near complete.

We are supposed to accept that our leaders are working in our best interests, but having gone through the Part M process I am cynical, to say the least.

Trust us, they say, and each time we get shafted, so forgive me for doubting any statement emenating from EASA or the EU

IO540

17th Nov 2011, 21:32

We heard a lot of good stuff during the latest FCL debate about how unacceptable EASA's proposals were. But when the crunch came, no-one actually challenged them and the proposals were voted through, even though they are still half-baked.That's because EASA did an under the table deal with the MEPs, to get their votes.

Quite what the deal was I don't know but it would have contained various fairly standard (in politics) elements e.g. promises of measures to alleviate the fairly draconian measures being proposed.

Of course EASA can go back on those promises, because a few years down the road all of the elected members will be back home on the golf course and playing around with other projects.

I am sure the Romans had this to a fine art, 2000 years ago. The only difference was that

- there was no internet
- there was no TV recording Mr Goudot's "little test" garbage
- if enough people didn't like you, they actually stabbed you in the back :)

What I find disturbing is that the worst and most anally retarded gravy train riders from e.g. the UK CAA and certain UK organisations involved in certification have emigrated to Cologne...

Pace

17th Nov 2011, 21:32

The 'problem' is that the obvious end-game is disbanding the national CAAs.

What including the French ones?

That's because EASA did an under the table deal with the MEPs, to get their votes.

That is a reflection of the desperation of EASA and a confirmation of the mess they are in.
Look at the Carbon footprints taxes! The FAA have already told EASA to get stuffed and that lot will collapse like the rest. A total shambles like the rest of Europe at present run by a bunch of headless chickens.

The IMCR is the least of our worries in Europe and the picture we will have 2 years down the line will not be anything like we have now.

Pace

IO540

17th Nov 2011, 21:34

No, France is exempt.

Ask Greenpeace ;)

FREDAcheck

17th Nov 2011, 21:36

Trust us, they say, and each time we get shafted
An American friend of mine used to say: "When anyone in a position of public responsibility says 'trust me' I instinctively reach for my gun".

Timothy

17th Nov 2011, 22:17

I think you are all missing the purpose of Mode S.

Last Sunday I was flying north towards MAY, on my way to KB, squawking 0012, listening out on LGW Director.

The controller says "Hello Timothy, would you like to go direct Biggin?"

What a narrow life you lot lead! :p

But actually my mentioning Mode S was only illustrative of a possible issue where one grouping may not see eye to eye with another.

421C

17th Nov 2011, 22:17

So what you are saying is you want a concise reply, but you don't like the reply you got? No, that is as removed from what I said as it is possible to get. OK, so let's see what you said:
With regards the IMCr and the CAA as I said earlier their reply is certianly concise after nearly three years of this process - the CAA doesnt know. http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/wink2.gif Well if they dont know, I guess no one knows. Worringly one suspects they do know, or have a jolly good idea - but they are not saying. That would be reasonable at the start of this process, it would be reasonable after a year of consultation, it might be reasonable after two years of consultation but it is no longer reasonable.
That reads to me like
a) you acknowledge the answer is concise, which is what you wanted
b) you don't like their answer.
That's all I wrote. How is it "as removed from what you said as is possible to get"? Did you like their answer? Did I misread that in the para above?

If, as you suggest, the Euro IMCr was never part of the process, then you have demonstrated even more convincingly that the process was flawed. No, that is the opposite of what I said. There was a structured process to review what the standardised EASA FCL qualifications should be. The IMCr was reviewed and rejected in that structured process.

You cant embark on a structured process that ignores elements that must be resolved, and if you didnt realise in the first palce that those elments would need to be addressed or sought to exclude them for political purposes then the process was flawed from the outset.
They did embark on a structured process. It didn't ignore the IMCr. It did realise that it needed to be addressed. It didn't seek to exlude it. However, in including and addressing it, they rejected it. Your problem is that you can't accept that a legitimate process could reach an outcome other than the one you want, therefore you keep pointing to conspiratorial/political/process flaws. The EASA FCL process was one of standardisation or integration or harmonisation, call it what you will. It's happened hundreds of times in the EU and it happens all the time in the private and public sector to organisations that are integrated or merged. In such a process a heterogenous set of things get harmonised into a homogoneous one. That means that some of the old individual things get rejected. There you go. It happens. You may not like the decisions the process arrived at - I don't either - it doesn't mean the process was illegitimate. The UK has accepted this kind of outcome as part of joining the EU.

At the start of the process everyone knew national qualifications existed. They did. But what you don't grasp is that, very obviously and directly, being part of the EU means being subject to harmonisation processes that can abolish national things that aren't accepted as part of the harmonised European model.

EASA saw fit to abolish national qualifications whilst retaining the option to encompass these qualifications within EASA qualifications in some shape or form. Not quite, it's what the EU told EASA to do when the EU law was passed that extended EASA's scope to FCL.

At a very early stage it was therefore clear that the future of the IMCr would have to be addressed "Addressed" is different from "preserved". It was addressed in FCL and rejected. That's my point about the difference between a process being "illegitimate" and your not liking the outcome.

and more especially thought would need to be given to those who already held national qualifications Thought was given, just not urgent priority. Unfortunately, EASA's more urgent priority has been grinding through the regulatory process for Part FCL, Part OPS, Part ARO, etc that it has to produce to a tight deadline. Individual national conversion and grandfathering was a secondary point because it is not relevant to most countries in the EU, given they fully implemented JAR-FCL 10 years ago and they don't have anomolous non-JAR-FCL qualifications. The UK is one of 27 countries, and the IMCr is an issue which is confined to a segment of UK GA. It may be at the top of your priotity list, but isn't it parochial to think it had to be a big priority for EASA

EASA had ample opportunity to set out their proposals for addressing this issue - so far as I am aware they failed to do so, and have still failed to do so.

How can you say "they have failed to do so" when the following words appeared in Para 7 of the FCL008 NPA in September:

Although the conversion of existing IMC ratings is not within the scope of this task, the Agency is aware that this issue is closely linked to it. This NPA provides several options for pilots with prior instrument experience to be credited towards the new ratings. However, it should be mentioned at this stage that a conversion of existing IMC ratings is already covered by the draft Commission Regulation laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council. This draft Regulation clearly defines that Member States should convert existing licences and ratings into Part-FCL licences and ratings. It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges.
The irony is that despite your endlessly portentous criticisim of just about everyone and everthing involved (AOPA, EASA, the CAA, the process, the clarity, the communication...) the outlook at present seems to be pretty much what has been communicated for the last couple of years
- an FCL008 improvement over FCL001, in offering a less onerous full IR and a sub-IR rating which is, however, not an IMCr
- a very likely grandfathering solution for the IMCr
- no prospect visible for preserving new IMCr issues in the future (other than for Annex II aircraft) but UK people still trying

Fuji Abound

17th Nov 2011, 23:04

421c

Why do you make something so simple so complicated?

Easa rejected the inclusion of the imcr at an early stage. Had they consulted and had their rejection been transparent it would have been clear (at any early stage) the void left was untenable. The eir and the grandfathering of the imcr was never on the table when the imcr was rejected, or certainly not publically. Both arose because easas rejection was untenable. Had the process been transparent it would have been clear much earlier that the proposals were untenable and we would not be in the mess we are now in.

Your attempt to rewrite history is therefore simply not supported by the facts.

As to your reference to easas statement that really is clutching at straws. The straw of a statement issued less than one month ago the clarrity of which at best leaves a great deal unanswered.

That reads to me like
a) you acknowledge the answer is concise, which is what you wanted
b) you don't like their answer.
That's all I wrote. How is it "as removed from what you said as is possible to get"? Did you like their answer? Did I misread that in the para above?

That reads to me ironry, but perhaps too subtle.

Clearly you have convinced yourself the process was not flawed and i am not going to change your mind. I suspect you are in a very small minority, but that is for others to say.

I guess on this one we couldnt be further apart so best left there.

;)

As to portentous i do see elements of the process and of those involved as sinister. There are very well publicised threads on this forum were committee members of aopa are on record of promoting very different views from aopas rank and file members and from the views eventually adopted by aopa. There are numerous examples of aopa changing their stance on the imcr, and there are very well publicised examples of statements made by easa that are at best misleading.

Politics is a sinister business - i am surprised you could possibly believe otherwise.

Finally i am obsessed with the imcr because it is the subject of this thread. I have no illusions that easa are a great deal less obsessed and no doubt in terms of the political components of the process (i prefer that to portentous) that they have far more pressing issues. The imcr just so happens to be the point of discussion. Pace and io540 will doubtless be only too delighted to help you out on n reg issues. :)

flybymike

17th Nov 2011, 23:27

The fact remains that less than 10% of the GA population sees fit to join
I find that figure surprisingly low. How many members does AOPA have, and how many active GA pilots are there?

flybymike

17th Nov 2011, 23:28

but the whole is greater than the sum of the constituent parts.

I think therein are words of considerable wisdom.

but mathematical impossibility.

421C

18th Nov 2011, 10:59

Why do you make something so simple so complicated?

Easa rejected the inclusion of the imcr at an early stage. Had they consulted and had their rejection been transparent it would have been clear (at any early stage) the void left was untenable. The eir and the grandfathering of the imcr was never on the table when the imcr was rejected, or certainly not publically. Both arose because easas rejection was untenable. Had the process been transparent it would have been clear much earlier that the proposals were untenable and we would not be in the mess we are now in.

Your attempt to rewrite history is therefore simply not supported by the facts.
It is simple, but you aren't reading or grasping my replies. Let me try line by line, with your text in italics

Easa rejected the inclusion of the imcr at an early stage
The FCL001 working group, responsible for the first draft of EASA Part FCL rejected the IMCr as an FCL qualification. I am glad we agree on this simple point.
Had they consulted and had their rejection been transparent
This is you rewriting or not grasping history. The FCL NPA was published. It transparently DID NOT include the IMCr. They DID consult. The FCL NPA went through the whole CRT-CRD process leading to a Final Opinion that then went through the EU Comitology process.
it would have been clear (at any early stage) the void left was untenable.
It clearly was tenable to the European Union since Part FCL became EU law. You mean it was "untenable" and "unnacceptable" to the IMCr minority interests. I agree. There is no law of the political universe that nothing can happen which some minority consider "untenable".

The eir and the grandfathering of the imcr was never on the table when the imcr was rejected, or certainly not publically.
That's right. We agree. So what? The first step in the process was to produce a draft Part FCL. They did that. It was a subsequent matter to deal with problems arising from that.
Both arose because easas rejection was untenable.
So EASA conducted the FCL process which produced the result it did. They got feedback that IFR qualifications needed to be made more accessible and feedback that UK stakeholders were unhappy giving up the IMCr. So the FCL008 process produced the EIR and CBM IR and the parallel process of negotiating transitions has suggested the IMCr grandfathering mechanism.

Had the process been transparent it would have been clear much earlier that the proposals were untenable and we would not be in the mess we are now in.
Where exactly was the missing transparency? The outcome has been perfectly clear that EASA Part FCL doesn't include an IMCr. You keep using this word "untenable". "Untenable" to you, "untenable" to IMCr holders fine. But clearly the Part FCL outcome was tenable because
a) the European Parliament passed it
b) the UK didn't threaten to leave the EU over it
and we would not be in the mess we are now in.
Relative to the Basic Regulation which imposed a standardised European FCL system and requirements for FRA operators to comply, and relative to Part FCL which was essentially a cut&paste of JAR FCL with a few bits of gold plating and some improvements like the LAPL, we have made some useful progress. We have the EIR and CBM IR, we have the outlook for IMCr grandfathering described in the NPA. So the next step is to secure those outcomes. Sure, relative to a parallel universe in which the Basic Regulation hadn't been enacted, or a parallel universe in which EASA had copied Part 61, or a parallel universe in which the UK government chose to expend the political capital it would have taken to ringfence and assure the IMCr, we are in a mess. But given the universe we are actually in, the present outlook since the NPA was published seems encouraging relative to the outlook before it was published.

As to your reference to easas statement that really is clutching at straws.
It's harder to have a useful discussion with you when you don't even accept the basic meaning of the English language in what you have written. You said "EASA had ample opportunity to set out their proposals for addressing this issue - so far as I am aware they failed to do so, and have still failed to do so." I pointed out Para 7 of the NPA. Their proposal is a restricted EASA IR giving IMCR holders grandfather privileges. How can my pointing that out be "clutching at straws". Isn't it a factual and obvious counterpoint to your writing "so far as I am aware they failed to do so"? I would have thought it a useful improvement in your awareness?

The straw of a statement issued less than one month ago the clarrity of which at best leaves a great deal unanswered
It's your old problem of clarity vs. transparency. They have published an unfinalised proposal. Not every detail is clear, although I find the essence pretty important and useful. So, as I said previously, the choice you have is between transparency (publishing interim things where not everything is clear and finalised) and clarity (publishing nothing until the final instrument is enacted and everything is clear and certain). They did the former and you say it's "not clear". If they'd done the latter, you'd have said they weren't being transparent. What's the point of your endless pursuit of an incompatible combination of clarity and transparency - ie. knowing, at the same time, what the end result is and knowing the steps of the process that is deriving the end result? Really the only substance is one of timing. EASA could have tackled it earlier. Well, launch a campaign to complain about that. I think you are missing the fact is there is a vast amount of incomplete regulatory work - on the implementation of FCL, on the FCL008 NPA, on Part MED, on Part OPS, on Part ORA. We are in a process were few end outcomes are certain and clear. The issues that affect all of Europe are probably a greater priority than the issues that affect just the UK. Are you surprised?

Finally i am obsessed with the imcr because it is the subject of this thread. I have no illusions that easa are a great deal less obsessed
I did not use the word obsessed, so I don't know why you bring it up. I merely thought it helpful to point out that what you interpret as a conspiracy of opaqueness, in not having the clarity you want with the transparency you want at the time you want it, is probably more the result of a regulatory agenda in Europe in which the long list of things that need to be completed and clarified doesn't rank the IMCr (unsurprisingly) as far up as you would like.

I am not writing all this to defend EASA. I have a myriad of things I would like to see changed in how European GA is run and regulated. Probably much the same as any of us. I am writing to suggest that what you percieve as a conspirancy to deny you clarity and transparency is simply a very large and complex process in which the IMCr issue is a minor one that is not addressed with the priority and vigour you would like. Given that, I think AOPA and the UK CAA are doing a pretty good job trying to push the IMCr forward against 26 other countries for whom, unsurprisingly, it is a distraction and nusiance relative to the huge task of implementing EASA regulation.

brgds
421C

BEagle

18th Nov 2011, 14:05

.....Part FCL which was essentially a cut&paste of JAR FCL.....

If only it had been, as DG TREN told the EASA Management Board it should be, we wouldn't have had this IMCR problem!

Having just left another largely fruitless meeting with the €urocrats in Köln, all I can say is that anyone with a well-maintained CofA Annex II aeroplane should count themselves lucky to be free of the utter nonsense of EASA!

IO540

18th Nov 2011, 14:24

soaringhigh650

18th Nov 2011, 14:34

should count themselves lucky to be free of the utter nonsense of EASA!

But hey if it wasn't for EASA the more accessible instrument rating qualification wouldn't have been proposed?

I think people do need to owe them a whopping thumbs up in this respect.

thing

18th Nov 2011, 14:36

Dons tin hat and retires to bunker.

IO540

18th Nov 2011, 14:42

But hey if it wasn't for EASA the more accessible instrument rating qualification wouldn't have been proposed?

Nobody would disagree with that - if it wasn't for EASA first screwing many thousands of FAA licensed pilots around Europe.

EASA didn't have to do it that way round. It's an inexplicable and totally arrogant c0ckup.

Same with the IMC Rating. They abolish that first and then "talk about" concessions to replace it. It's a totally stupid way to go about things.

flybymike

18th Nov 2011, 17:00

Peter, "Tail number" is such a frightfully American expression old boy.

mad_jock

18th Nov 2011, 17:33

The perm hex code in the mode S transponder is linked to the registered owner and Reg.

So even if you are not talking and are on 7000 they know what the reg is.

Thats not to say the controller didn't then link the reg to the name and offer the direct routing.

IO540

18th Nov 2011, 17:37

The perm hex code in the mode S transponder is linked to the registered owner and Reg.Technically that is true but I gather that UK ATC do not have access to the database which does the Mode S code to the aircraft operator conversion.

It would be funny if they replied to V. pilots with "Good Morning Mr Branson, where would you like to go today" :) :)

Of course, how else would their computer know where to send the bills? (which is their motivation for Mode S) That is AFAIK not the way it works in Europe. A good number (IIRC) of European countries have no interest in Mode S and don't require it in their airspace. The Eurocontrol IFR enroute billing (> 1999kg) is done by a unit which runs a database of aircraft regs (tail numbers ;) ) and maintains a correspondence/billing address for each one. For foreign reg planes, that process will be very haphazard because the tail number does not lead to the aircraft owner; the bill instead goes to the US trustee who then sends it onto the operator with a stroppy letter, and this encourages the operator to contact Eurocontrol and update his details.

I dare say Eurocontrol have a lot of fun chasing after the more elusive planes... I wonder if they refuse to accept a flight plan for somebody who has not paid the bill? Could be quite a problem if you bought a used plane which is over 2T.

Timothy

18th Nov 2011, 21:39

The controller says "Hello Timothy, would you like to go direct Biggin?"
How do you configure your name in the Mode S transponder?

I think it's far more likely that the controller knew you personally and recognised your tail number which is plastered all over the internet. I've had the same sort of "hello" from a Scottish controller earlier this year, and there is another controller in a certain country not far from the UK who send me a funny email every time I fly through his airspace. It's only because they know the tail number from my trip writeups. There is nothing in the Mode S data.
Peter,

I sometimes despair of your humourless literalism.

Yes, the controller knew who I was because I have flown him and we are, among other things, Face Book friends.

If I had been squawking C he would not have recognised me, because of S he did.

But really it was what we in the West call a "lighthearted comment" :ugh:

GeeWhizz

18th Nov 2011, 22:51

If I had been squawking C he would not have recognised me, because of S he did.

Didn't realise mode S could be 'squawked'. A mode S transponder is a mode S transponder isn't it? A transponder that does A and C with secondary information available to ATC as input from the pilot or aircraft system.

I visited Manchester centre once before it moved to Prestwick and saw mode S in action. It was being used mainly to see what level airliners were climbing to under the control of someone else, rather than having to turn their head and talk to a human. The mode A to reg/callsign conversion was simpler too as no one had to do it manually (example case above).

What else does or should mode S do?

Timothy

18th Nov 2011, 22:59

What Elementary and Extended Mode S can do is a whole different debate, but the point I now wish I hadn't made is that it carries your registration/flight number, so the controller can see who you are, so he can recognise you as a friend and give you special treatment.

GeeWhizz

18th Nov 2011, 23:11

Fair enough I'll look forward to learning about it. In the mean time, I'd better go make some friends ;)

Fuji Abound

18th Nov 2011, 23:20

421c your argument relies on your assertion easa consulted. They may claim they consulted but the consultation was clearly ineffective. Had the consultation been effective it would have been clear the proposals to abolish the imcr were untenable. You haven't grasped that in any process claims can be made that certain steps have been taken. Easa were not clear on their proposals and the process of consultation was clearly ineffective or else the problems with which easa are not faced would have been resolved much sooner. To put it very simply if you get towards the end of a process and find you need to substantially change the proposal chances are you got it horribly wrong from the outset.

There are numerous instances in recent times of governments pressing ahead with legislation. Of course they claim the proposals were transparent and the consultation encompassing and of course it was nothing of the sort. Your argument is nieve if you really believe otherwise. If easa had an inkling of the problems it would cause them the last thing that would want to engage in is open and frank consultation.

We are discussing the imcr. I've said I agree it is a very small part of the process, and I don't doubt not of great priority. Never the less I suspect easa has been surprised by the amount of time they have now had to committ to the issue.

No the mess surrounding the imcr, the eir, and the so called ir lite all originate from a defective process at the outset that much is clear or else these issues would not only now have come to the fore front.

It is a shambles and we all know it.

Timothy

18th Nov 2011, 23:23

Isn't a prerequisite of something to be "so-called" that it is actually called that?

Fuji Abound

18th Nov 2011, 23:27

Yes, what are they calling it?

IO540

19th Nov 2011, 07:17

If I had been squawking C he would not have recognised me, because of S he did.I don't think so. I am not an ATCO but, AFAIK, in every context in which an ATCO is talking to you, he already has your tail number anyway. Either it was passed to him on a handover (and in the UK VFR context, with your Mode A/C squawk) or you have just given it to him on your initial call to his unit.

Even I know your tail number, and I have never seen your plane and I don't do any social networking (thankfully).

Humourlessly literal, but inaccurate?

so the controller can see who you are, so he can recognise you as a friend and give you special treatment. That could work both ways ;) There is a well worn story going around about a certain well known female ATCO who kept making passes at airline pilots landing at her airport, and every one who turned her down got extra time in the hold. If you saw her picture, you could see why all of them turned her down, though I am sure she had a great personality - as they say on the dating sites ;)

It was being used mainly to see what level airliners were climbing to under the control of someone elseYes; Mode S enabled NATS (or somebody) to develop some clever software for displaying traffic, with holding stacks, and some slick features because they can see the autopilot settings so if e.g. you clear an airliner to FL300 and the pilot sets the altitude preselect to FL310, the ATCO can - in theory - spot it. And the checks can potentially be automated.

But all of this extra capability needs Enhanced Mode S, which EASA specifically bans from 99% of "GA" aircraft. Some foreign reg planes radiate some of the extra parameters (because in the USA, where virtually all avionics is made, the Elementary / Enhanced distinction doesn't exist; it was invented by EASA who did not realise what equipment actually existed :ugh:) but they usually don't radiate autopilot settings and such.

They may claim they consulted but the consultation was clearly ineffective. EASA has to go through the motions but in the end they tend to do what they like anyway if the matter has any political connotations and they are doing it in support of the anti US stance prevailing in the EU, and that applies to the majority of EASA's regulatory output. Occassionally one can pick them up on something which is politically neutral, and then they have been shown to listen.

GeeWhizz

19th Nov 2011, 07:40

IO540 as useful and knowledgeable as you are I have to make some additions....

I don't think so. I am not an ATCO but, AFAIK, in every context in which an ATCO is talking to you, he already has your tail number anyway. Either it was passed to him on a handover (and in the UK VFR context, with your Mode A/C squawk) or you have just given it to him on your initial call to his unit.

Having an S transponder that has the aeroplanes reg stored within it can be viewed by any ATCO that has the equipment to display the information. One of the aeroplanes I fly has a mode S xpdr and it asks for confirmation of the reg when it's initially switched on, for this purpose.

Yes; Mode S enabled NATS (or somebody) to develop some clever software for displaying traffic, with holding stacks, and some slick features because they can see the autopilot settings so if e.g. you clear an airliner to FL300 and the pilot sets the altitude preselect to FL310, the ATCO can - in theory - spot it.

Just to expand on my previous comment. The Manchester ATCO was trying to push his aeroplane higher with another one crossing its track, climbing, and could potentially erode standard separation (due to laziness of not co-ordinating the movement with the other controller). So he pressed a magic button and the S displayed what was going on. This was something like 3 years ago now when I believe S was used by some liners and not others so the silent game was a bit hit and miss (more misses than hits though). Although now, with your kind explanation, I understand how the S returned the information.

Thread drift I know so I'll shut up... back to EASA and political doo-dahs and what-nots :\

Timothy

19th Nov 2011, 07:49

in every context in which an ATCO is talking to you, he already has your tail number anyway.
Oh for pity's sake Peter, don't you ever wonder to yourself why you get stuck in this kind of loop?

As I said, right at the beginning, when I made this flippant (look it up) passing remark, I was approaching the LGW Zone squawking 0012, listening watch, so receiving no service. He was not talking to me. He started the conversation because he saw what you persist in calling my "tail number" but what we in this part of the world call "registration".

AFAIKAs I have said before, your belief in the superiority of your knowledge and understanding over all others is a marvel to behold.

IO540

19th Nov 2011, 08:15

One of the aeroplanes I fly has a mode S xpdr and it asks for confirmation of the reg when it's initially switched on, for this purpose.

You are right - the reg is always stored.

Or should be - it may not always be configured right. Also the 24 bit code may be wrong; some poster on the flyer forum once reported that his code was duplicated by somebody else.

421C

19th Nov 2011, 09:14

421c your argument relies on your assertion easa consulted. It's not an assertation. It is a blindingly obvious matter of public record that there was a long consultation process following the FCL NPA, you can read about the process and find the thousands of CRD replies here: EASA - Comment Response Documents (CRDs) and Review Groups (http://www.easa.eu.int/rulemaking/comment-response-documents-CRDs-and-review-groups.php)
Are you asseting that EASA didn't consult?

They may claim they consulted but the consultation was clearly ineffective. Had the consultation been effective Well, EASA FCL is now EU law, so clearly the process was effective in that it fulfilled the obligations EASA had in a way that was satisfactory both to the member states in the Comitology process and the European Parliament.

it would have been clear the proposals to abolish the imcr were untenable. Do you think that, having discovered the word "untenable", you now command some special magic power of argument? You keep repeating it over and over. If we are to have a discussion in the way people normally do, you are going to have to help me understand what you mean? Any of us can assert that anything is "untenable". So what? What exactly is untenable about EASA FCL?

Easa were not clear on their proposals and the process of consultation was clearly ineffective or else the problems with which easa are not faced would have been resolved much sooner.
They were clear. No IMCr. Grandfathering to be discussed as part of the transition process. Do you really think the IMCr is a "problem" EASA faces? Why? FCL is EU law. It's over.

To put it very simply if you get towards the end of a process and find you need to substantially change the proposal chances are you got it horribly wrong from the outset. No, that isn't what happened. It was recognised that the FCL001 timeline did not allow a review of instrument qualifications beyond what was in JAR-FCL and beyond the review and rejection of the IMCr. So they set up FCL008 to address some of the issues around instrument flying.

Much of the opaqueness is inside your own mind. The outlook has been pretty clear for years. Not months, years:
- IMCr rejected as a Euro ratng
- FCL008 to propose some new European IFR quals
- IMCr to be grandfathered one way or another, hopefully

Apart from repeating that it is all "untenable" and EASA got it all horribly wrong, and there is no "clarity", do you have any specific points to make on this subject? It would make the discussion more interesting....

Pace

19th Nov 2011, 10:33

421C

There was a very wise saying by Douglas Bader " The Law is for fools to obey and wise men to question".
Yes the whole thing was past by parliament as only the whole could be past not bits removed.
There were many known opponents who were talked into supporting "whole lot" being passed through the European Parliament as their choice was to accept the lot or reject the lot with disasterous consequences for EASA.
Backroom deals? Of course! promises false or true? Of Course.
Legal yes? But NO as I have had through good authority that EASA have hit a brick wall on N reg Commercial pilots who are resident in Europe with the legality of what they are trying to do. That is why so little is coming forward from EASA in that area.
My main concern is that EASA are supposed to be a safety regulator. That is their mandate.
Yet their motives have been far from safety based.
The French apalling safety records for VFR flight compared to the UK IMCR rated VFR pilots is one example.
EASAs new EIR IMO is badly thought out and dangerous.
Their attack on the N reg fraternity which has NO basis on safety whatsoever!
Maybe I am more cynical and un trusting than you but a load that has happened through EASA since they were first threatened with disbanding for trying to reinvent the wheel leaves a bad taste in my mouth.
Only time will tell how all this pans out!

Pace

abgd

19th Nov 2011, 10:40

The rumour I'm hearing is that we'll be able to complete an IMC rating (and retain it) if we start it before April 2012 and complete it by April 2014?

I'm currently on the way to completing my PPL but I don't want to be rushed into doing the IMC - I'd like a little while to consolidate first not to mention saving up the pennies. So I was wondering whether anybody knows what the criteria are for having 'started' an IMC course - for example, if I could get the ground exam done and one lesson now would that be sufficient?

Pace

19th Nov 2011, 10:45

ABDG

i am sure others will detail more than me but you must have a current IMCR not having started a course to qualify!
The whole crazyiness of this is as far as I can see if you have rights to fly as before within UK airspace and also hold the new EIR for enroute you will literally hold a UK IR as you will be able to do everything an IR holder can do other than break IMCR RVR limits ( cloud base not proveable :E

Pace

Timothy

19th Nov 2011, 10:52

I would say that you are playing with chance.

I would have thought it vanishingly unlikely that the NPA will be adopted, and UK law changed, by April 2012.

Therefore it makes sense that April will be irrelevant to what happens.

How long after that you have is anyone's guess, but I would certainly put the rumours down to guesswork until we hear something definitive.

Pace

19th Nov 2011, 12:41

The whole crazyiness of this is as far as I can see if you have rights to fly as before within UK airspace and also hold the new EIR for enroute you will literally hold a UK IR as you will be able to do everything an IR holder can do other than break IMCR RVR limits ( cloud base not proveable

ABDG

I would rush through your IMCR because of the above (I would like comments from others)

If you have your IMCR then you get the rights within UK airspace to take legal approaches but not to fly airways in class A airspace.

If you have the IMCR EASA will give huge allowances for the EIR which basically allows you to fly IFR enroute.

So as far as I read this as long as you fly within the UK the IMCR will allow you not only to fly legal IFR approaches and departures but the EIR will allow you to fly in class A airspace meaning you have a full IR for literally the cost and difficulty of an IMCR.

Has to be a good deal by anyones standard or am I missing something??

It really just shows the stupidity of the whole EASA thing?
Brilliantly thought out by EASA (I THINK NOT)

Oh well you will soon be mixing it with the likes of Easy Jet on a departure out of Luton in the club PA28 and fly your way to Aberdeen (how many hours do you have) :ugh:
If weather gives 200 overcast just say you were visual at 500 ;) crazy world

As for me who has thousands of hours and ferry experience around the world flying N reg Jets as a Captain if EASA has their way I am incompetant and should be treated like you slogging through 14 exams as I said what a Crazy World we live in! I am sure 421C is right and EASA are wonderful :E and cannot put a foot wrong!!!

Pace

Timothy

19th Nov 2011, 12:46

Whatever the politics and rights and wrongs, my specific advice to anyone who expects to want to get an IFR qualification at any time in the future would be to start and complete an IMCR course as soon as possible.

It is all a matter of risk and chance, but the IMCR can only do you good, and the worst case scenario is that it is lost by April.

Taking everything together, now must be a great time to do it, from a risk management point of view.

Please don't take anything I say as a commentary on the rights and wrongs, it is simply the advice I would give, given the way things look today.

bookworm

19th Nov 2011, 13:06

In so far as it has any similarity with the Euro crisis it does in this much - a Europe which is bereft of the political will to face up to its United responsibilites because the politicians cant escape their national interests.

I'm intrigued by the idea that the fault in all this lies with "national interests". The European system is indeed subject to national interests, because of its Council structure. So in the field of aviation regulation, what EASA proposes as an opinion to the Commission, and what the Commission gets into law, is subject to Comitology in the EASA Committee by national representatives.

The alternative would be to move aviation regulation entirely into federal government, and give member states no influence on what becomes law. The USA has done this, and it has its advantages. And, guess what? The FAA has no IMC rating, no matter how much Rhode Island wants to have one. Not even "grandfather rights".

Be careful what you wish for.

Pace

19th Nov 2011, 13:12

The alternative would be to move aviation regulation entirely into federal government, and give member states no influence on what becomes law. The USA has done this, and it has its advantages. And, guess what? The FAA has no IMC rating, no matter how much Rhode Island wants to have one. Not even "grandfather rights".

Be careful what you wish for.

Bookworm

FAA in total? WORLDWIDE! The most sensible option for the health of aviation and low cost in comparison , Roll it on ;)

Pace

Timothy

19th Nov 2011, 13:32

...and definitely get the IMCR and the EIR before the FAA takes over, as neither option is available under that regime.

thing

19th Nov 2011, 14:44

Taking everything together, now must be a great time to do it, from a risk management point of view.

Doing mine now for that very reason. Quite enjoyable actually, would recommend it if anyone is thinking about doing it.

Timothy

19th Nov 2011, 14:45

Make a virtue out of a necessity! ;)

thing

19th Nov 2011, 14:59

Absolutely, and if as you say the worst case scenario (which I doubt) is that the IMCR is scrapped in entirety then I still have the training to not kill myself in bad weather should the need for that training arise, whether I would be using it illegaly or not. Regulation doesn't come into it when you're looking for somewhere to land in 1800 mtr vis and 500 ft cloudbase.

Timothy

19th Nov 2011, 15:57

...or indeed in 50m and V////

Timothy

19th Nov 2011, 16:32

But the new competence based IR will be just as appropriate to PPLs as the FAA/IR.

So, if the argument goes that if we had an FAA style IR, we have no need of the IMCR, there will be a certain amount of wind out of quite a few sails.

IO540

19th Nov 2011, 16:50

It takes more than an FAA IR - like IR to make the IMCR obsolete.

Start with the ability to do it at any flying school (no special approval needed).

The FTO system, and the forthcoming ATO system where the ATO will need a special approval (£££) to teach the CBM IR, doesn't compare because it makes the "IR" a residential (hotel stay) project for most punters.

Then add the ability to do it with freelance instructors.

Etc.

Time will tell what we get. But anybody holding back on doing an IMCR in the hope of the current IR proposal making it to law is IMHO very foolish.

Fuji Abound

19th Nov 2011, 20:42

So they set up FCL008 to address some of the issues around instrument flying.

Exactly, you have nearly got there.

No imcr, no grandfathering, no eir, just the ir lite (well maybe) that is where it started, lets see where it ends.

jecuk

19th Nov 2011, 20:48

Interesting discussion. I have been surprised here that the IR is seen as a commercial qualification. In the US and Australia it is a way for PPLs to improve their flying, options and safety as well as being a commercial qualification.

IO540

19th Nov 2011, 21:31

I have been surprised here that the IR is seen as a commercial qualification. In the US and Australia it is a way for PPLs to improve their flying, options and safety as well as being a commercial qualification.

Absolutely correct observation :ok:

The difference between the USA and Europe is that in the USA the hallmark of a "professional pilot" is the ATP, whereas in Europe the ATP is what you are given for nothing (essentially) once you have

- got a CPL/IR (14 exams, CPL, IR)
- accumulated 1500hrs TT of which 500hrs are multi crew (which obviously means having to get an airline or possibly a business jet job)

So Europe had the dilemna as to which flagpole to nail the "professional pilot" status. All it had was the CPL (which is an essentially useless qualification without an IR, and anyway is mostly a precision dead reckoning exercise), or the IR, so obviously it went for the IR as the separator between real men and the sheep.

Give it many years and you have a massive emotional and regulatory attachment to the IR, which became a device openly intended to stop anybody from entering the airline pilot system who is less than absolutely determined/obsessed to become an airline pilot.

That is the issue around the IR. It is 100% politics and bullsh*t. All the rest is detail.

Now, after more years than most can remember, EASA is unravelling some of this, which is a good thing, but the proposal has a long way to go through the rulemaking sausage machine.

Johnm

19th Nov 2011, 21:31

Interesting discussion. I have been surprised here that the IR is seen as a commercial qualification.

Yup when I did my IR aged 62 the school couldn't understand why someone already too old to be a commercial pilot would want to do that. I have flown my little aeroplane in class A in the clag quite happily ever since and airways across Europe is SOOOOO much easier than VFR:ugh:

GeeWhizz

17th Dec 2011, 23:28

I think its time to bring this thread to the fore.... again.

If I've read it correctly, having a quick flick through CAA Response to EASA NPA 2011-16 (http://www.caa.co.uk/docs/620/20111214EASACRTNPA201116V3.pdf) it seems that the CAA is going to retain the IMC Rating. It’s justification being a ‘stepping stone’ to the EIR, CBM IR, or full IR.

It also appears to exploit the rulemaking inclusion that individual States may continue to allow its members national ratings that can be used only within the issuing Member State, and any others by way of bilateral arrangements. This implies that the CAA will continue to issue IMCs and permit those already holding one its continued use. Now, as with NPPL, we just need to ask the French to be able to use it in their airspace!

Interestingly there is also mention of the EIR not requiring a night qualification or rating; possibly the most useful element to this debate as it’s clearly aimed at PPLs being eligible to fly IFR in IMC in all classes of airspace, rather than the usual marriage of an IR and the ATPL. One could be a PPL with an EIR and still only require a Class 2 medical.

Reading between the lines, the mention of EIRs having to display their competence at an emergency IAP is like saying "if they have to do them during the initial test, they should also be done during renewals. If they are to be done during a renewal it should be made a standard requirement for EIRs to be able to carry out IAPs - full stop"! :D

All in all a very good response (I think) by our ‘Competent Authority’ – well done!

BEagle

18th Dec 2011, 07:20

If I've read it correctly, having a quick flick through CAA Response to EASA NPA 2011-16 it seems that the CAA is going to retain the IMC Rating. It’s justification being a ‘stepping stone’ to the EIR, CBM IR, or full IR.

It also appears to exploit the rulemaking inclusion that individual States may continue to allow its members national ratings that can be used only within the issuing Member State, and any others by way of bilateral arrangements. This implies that the CAA will continue to issue IMCs and permit those already holding one its continued use. Now, as with NPPL, we just need to ask the French to be able to use it in their airspace!

Actually, the reason they've said that is because the French set a precedent with their lobbying for the amendment to Article 4. The CAA is now using this as a lever and you will note that their response, no. 427, was made after their other responses. That was as a result of certain lobbying from industry. There is no intention, at this stage, to seek further extension of IMCR privileges outside UK airspace.

Interestingly there is also mention of the EIR not requiring a night qualification or rating; possibly the most useful element to this debate as it’s clearly aimed at PPLs being eligible to fly IFR in IMC in all classes of airspace, rather than the usual marriage of an IR and the ATPL. One could be a PPL with an EIR and still only require a Class 2 medical.

Correct, the EIR was intended to be day only. However, it was pointed out that this wasn't much use in winter for Member States of northerly latitudes, so proposals have been made to permit night extension of the EIR for pilots who hold valid night qualifications. But no-one has ever suggested that holding a night qualification should be a prerequisite for the EIR, so the CAA's response in this context seems a little odd.

Reading between the lines, the mention of EIRs having to display their competence at an emergency IAP is like saying "if they have to do them during the initial test, they should also be done during renewals. If they are to be done during a renewal it should be made a standard requirement for EIRs to be able to carry out IAPs - full stop"!

Wholly incorrect. Industry was asked to provide agreed guidelines to the CAA for the 'Emergency IFR approach'. We concluded that there was insufficient EIR syllabus time for pilots to develop adequate proficiency in pilot-interpreted instrument approaches, we also stated that unapproved 'D-i-Y' GPS let-downs should be strongly discouraged. However, as availability of approved GPS approaches is likely to increase in the near future, use of such approaches for the ‘Emergency IFR approach’ should be reviewed in future years. Our recommendation is for a ground-based radar procedure; this can easily be simulated during revalidation / renewal checks if a suitable aerodrome is unavailable.

All in all a very good response (I think) by our ‘Competent Authority’ – well done!

Most of it is, but the wording of 411 is a bit odd. Also, I don't agree with their view in 418 regarding TMGs and the Sailplane Cloud Rating as there are better ways of discouraging inappropriate use of the SCR by TMG pilots. Others will be disappointed, no doubt, at the CAA's opposition to independent instruction outside an ATO.

IAOPA(EU) has submitted a response and AOPA(UK) has submitted a supplementary response. Both can be viewed by following the links at AOPA(UK) and IAOPA(Europe) - Response to EASA NPA 2011-16 (http://www.aopa.co.uk/index.php?option=com_content&view=article&id=574:aopauk-and-iaopaeurope-response-to-easa-npa-2011-16&catid=1:latest-news) .

421C

18th Dec 2011, 08:59

There is also a response from PPL/IR Europe available here: PPL/IR Europe - PPL/IR Europe (http://www.pplir.org/index.php?option=com_content&task=view&id=593)

GeeWhizz

18th Dec 2011, 11:08

Now, as with NPPL, we just need to ask the French to be able to use it in their airspace!
There is no intention, at this stage, to seek further extension of IMCR privileges outside UK airspace.

Added entirely tounge in cheek... right 'now' the French arn't going to be too helpful with anything, going by recent European events ;) Again for the EIR with IAPs - it's a nice thought, optimistic but nice.

Others will be disappointed, no doubt, at the CAA's opposition to independent instruction outside an ATO.

Some proposals have to be accepted. I think this is the 'give' part of the deal, whereas the insinuation that the UK will retain the IMCR regardless is the 'take' portion. Also with the proposed wording the CAA are keeping as many options open as possible.

411 reads like a good buttering-up IMHO, signalling a general acceptance of the NPA making the following recommendations seem rather specific when actually as before, they are keeping all of the options available... cleverly done.

Surely it's perfectly understandable for TMG rated pilots to have to obtain the EIR? If TMGs can fly in IMC on a 5hr SCR then SEPs should be able to the same also. It seems to be a matter of fairness and equality. OK so TMGs arn't going to like this much, and they shouldn't, but there'll be many IMCRs that can't fly in IMC on the continent on a 15 hour rating, when SCRs can do as they please all over the shop! It's important for an engineless craft to have the opportunity of gaining that little extra altitude where possible, but TMGs can climb and run away from IMC without fear of an unsheduled forced landing. Six and two threes?

I'll have a read of the AOPA and PPL/IR NPAs when I have a few more minutes to spare. I'm sure they'll be equally as interesting to read. :)