What's happening about those with UK CPLs/ATPLs with permanent IMC privileges?

[hugh flung_dung]

There must be many instructors like myself with a UK CPL or ATPL which includes IMC privileges. I asked the CAA what would happen to these in 2012 but did not get an answer; has anyone seen an authoritative statement?

HFD

[blagger]

HFD - I know this issue has been raised to the CAA. There is also the issue of those instructors who have removed the 'No Applied Instrument Instruction' restriction based on being an IMC holder or a CPL/ATPL with IMC priveleges and whether they will get an IRI on EASA conversion.

[Whopity]

Why would they get an IRI? Its a stand alone rating, they already have a FI rating with the privilege built in except that without an IR they will not be able to teach for an IR. If the IMC rating is retained in the next round of EASA talks, then they may be able to continue with their existing privileges; the answer is as yet unknown.

The built in IMC privileges do not exist under EASA but your UK ATPL will still be valid on an Annex II aeroplane.

[BillieBob]

As things stand right now an IMC rating cannot be attached to an EASA licence. It will, however, be able to be attached to a UK national licence post 2012 but then will be valid only on Annex II aircraft. There are a number of opinions and promises regarding the future status of the IMC Rating and, while much work is being done to protect the privileges already earned, where EASA is concerned, nothing is assured until it has been enacted into European law. To misquote the words of Sam Goldwyn, a verbal assurance is not worth the paper it's written on.

Regarding the 'No applied instrument' restriction, the same applies - current privileges will remain valid if the FI Rating is attached to a UK national licence but then may be exercised only on Annex II aircraft. Since, at present, the IMC Rating does not exist in EASA, the only qualification for which 'applied IF' instruction is relevant is the IR and, to instruct for that an FI will have to meet the additional requirements of Part-FCL for an IRI.

[blagger]

Whopity

As I understand it, the Applied Instrument restriction is a UK CAA hangover. Come the EASA changeover, all FIs will need to get a IRI rating on their licence alongisde their FI rating if they want to teach IF. This is already the case in other European countries under JAR-FCL.

Those FIs who have removed the restriction based on an IMC or UK CPL/ATPL IMC privileges have paid lots of money to do the IRI course and gain those instructing privileges - there should be a mechanism so that is recognised, even if it has to stay dormant until an IR is obtained.

[Whopity]

This is already the case in other European countries under JAR-FCL.

It varies from country to country. Some have the addition of an IRI rating, whilst others have the privileges embedded into the FI rating. The limitation found in UK issued licences is a hang over from the National Flying Instructors rating and occurred because the CAA's software was not amended on the implementation of JAR-FCL. They have had 11 years to fix it but haven't done so. If we look at EASA Part FCL it says in FCL 905.FI(h) that an FI may teach for the IR provided they have met a specific training requirement, no mention of requiring a separate IRI rating. FCL 905.IRI refers to the stand alone IRI rating much the same as in JAR-FCL; so it is not clear either way how it will be interpreted.

[MrAverage]

Just received email from the CAA with this link:

IN-2011/15: Publication of Website Information Concerning The Expected Effects of EU Legislation on Flight Crew Licensing | Publications | CAA

As I read it IMC will be valid on EASA aircraft, I'll just have to have a UK CPL alongside my EASA CPL. So much for centralisation.......

[BillieBob]

MrAverage - I don't understand how you can read the CAA paper in that way.

The proposed Part-FCL does not have an equivalent to the UK IMC rating. During 2009 an
EASA rulemaking working group developed proposals for a simplified European instrument
rating for private aeroplane and sailplane pilots. Towards the end of 2009 that activity was put
in abeyance so that the Agency could focus its resources onto the completion of Parts FCL,
MED, OR and AR. At the time of writing the proposals for the simplified IR have not yet been
published. It is expected that the proposals will be publicly consulted upon by EASA in the third
quarter of 2011 by means of a Notice of Proposed Amendment. When the rules are finalised in
the light of comments received, they should eventually appear as an amendment to Part-FCL.

In discussions with UK representatives and the CAA, the Agency has said that there should be
a means to take credit for the UK IMC rating to obtain the new European rating. EASA has also
indicated that, if the new European rating is more restrictive than the UK IMC rating, existing
holders of the IMC rating might be granted a restricted form of the full IR that would confer the
same privileges as the existing UK IMC rating. (Such a rating would also be subject to the
restriction that it could only be used to fly UK registered aeroplanes in UK airspace - as is the
case now with the IMC rating).

As I read it:

• Work on the 'simplified' IR has been put on hold and, in any case, is a fundamentally flawed concept
• EASA has said that there should (not will) be credit towards the 'simplified' IR for holders of the IMC rating
• Holders of the IMC rating might (not will) be granted a restricted EASA IR

There is absolutely nothing in the paper to suggest that the IMC Rating will continue to exist or that current holders will be able to exercise its privileges on EASA aeroplanes. Lots of assumptions and aspirations but absolutely no certainty - my previous comment regarding Sam Goldwyn stands.

[BEagle]

• Work on the 'simplified' IR has been put on hold and, in any case, is a fundamentally flawed concept

Yes, the proposals won't appear until June 2011. But whereas there's no reason to suspect that the 'simplified' IR is a fundamentally flawed concept, there's every reason to suspect that the EIR Death Rating most certainly is.

• EASA has said that there should (not will) be credit towards the 'simplified' IR for holders of the IMC rating

We don't know yet - the actual proposals won't appear until June 2011.

• Holders of the IMC rating might (not will) be granted a restricted EASA IR

This would be insufficient; there must be categoric assurance that anyone who holds, or has held, IMCR privileges will be permitted to revalidate/renew them as and when. The concept of an IR(Restricted to IMCR privileges in the UK only) is something I raised several years ago - it seems that only now are the CAA and EASA waking up to the idea!

[MrAverage]

Page 9 of 35 - 6.2 is surely encouraging isn't it?

[BillieBob]

there's every reason to suspect that the EIR Death Rating most certainly is.

It is to the EIR that I was referring. Despite the work being done on behalf of the IMC Rating, the balance of support in EASA is still with the EIR and there remains a very real risk that it wil be adopted.

We don't know yet - the actual proposals won't appear until June 2011.

As I said

This would be insufficient; there must be categoric assurance that anyone who holds, or has held, IMCR privileges will be permitted to revalidate/renew them as and when.

That may well be the final outcome but, equally, it may not. My point is that the €urocrat is a devious and untrustworthy beast and nothing that he says should be taken at face value. We cannot assume that the IMC rating will survive in its present form, or at all, although the hope clearly is that it will.

Page 9 of 35 - 6.2 is surely encouraging isn't it?

Not really, it describes a laudable aspiration and the last UK government showed us how much they are worth. It certainly does not justify your previous interpretation that the IMC Rating will be valid on EASA aircraft.

[MrAverage]

I better get my coat - and go back to not posting!

[BEagle]

My point is that the €urocrat is a devious and untrustworthy beast and nothing that he says should be taken at face value.

I would certainly agree with that assessment!