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Old 28th Mar 2007, 23:44
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IMC priveledges

Hi all, I was told last year by a greek icao inspector that from next year, the uk IMC privileges will extend to the whole of europe. Can anyone either confirm, deny or shed any light?
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Old 29th Mar 2007, 08:06
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It has been discussed but is unlikely to happen. The original suggestion was to add an IMC rating to the upcoming European Pilot License but the european representatives were very much against the idea, having the view that it would become a poor mans IR. What is more likely to happen is the IMC rating will disappear under EASA but a much more achievable PPL/IR is on the way imminently. Fewer exams, much more streamlined and content relevant to the safe conduct of IFR in CAS, no CRP 1/5 no planning for JAR/OPS and jet transport etc. Modular based training. The end result will be the same in IR terms , i.e a rating that allows the provide pilot to operate in CAS with the CAT at the same high standard but the route to achieve it will be much more FAA style in terms of access and relevance.
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Old 29th Mar 2007, 08:23
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bose-x,

I don't want you to give a hostage to fortune, but... what's the timescale for that new PPL/IR?

I can't wait! I'm going to start saving up...

Tim
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Old 29th Mar 2007, 08:25
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However, the real driver behind all this (kicking out N-reg planes from Europe) won't achieve this objective until EASA offers

- a straight conversion path to FAA licenses/ratings (at each level e.g. PPL, CPL, ATPL, IR)

- acceptance of FAA certification; great many planes esp. jets and turboprops just cannot go on G-reg etc due to non-EASA equipment

- alignment of JAA medical requirements to ICAO, like removing the pointless Class 1 audiogram for each ear, currently required for the IR; airline pilots get around this using the "demonstrated ability" option on renewals but this option needs to be made available on initial as well, as the FAA does.

Until EASA does all of this, any action against N-reg will just look like a DfT-style crude eviction of US aircraft from Europe, which will go down well (not) with Airbus trying to sell planes in the USA.

Technically the above is trivial to do. Politically it is very hard. By far the hardest job EASA has is to make things like FAA without actually labelling them with the "FAA" label which the Eurocrats hate so much.

IMHO nothing will happen for 3-5 years at least.
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Old 29th Mar 2007, 11:04
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IO we generally agree on most things but on this one we are not! Your timescales are way out.

The change to the IR is imminent. Massive changes are being made to the syllabus and the requirements as we speak.

It seems the ultimate goal is for EASA to remove non AOC operating N Reg aircraft to gain oversight of them. They intend to remove the biggest reason for private operators to be on the N Reg which is the IR. But this is an aside, the real reason for the changes is to make an IR in Europe a reality, learn from the FAA by encouraging more pilots to take up the IR and enhance overall safety.

The PPL/IR will be in line with the FAA IR in terms of access but the practical standards will still be JAA rather than FAA (the FAA test standard is the same as the IMC minima aside, the JAA is slightly tighter but virtually negligable).
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Old 29th Mar 2007, 12:57
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Wasn't the original implimentation date for EASA licences supposed to be Sep this year?
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Old 29th Mar 2007, 14:56
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bose-x

the FAA test standard is the same as the IMC minima aside

Having done both, I have to disagree most strongly, but I will leave it there. You know me and where I am coming from.

The fact is that nobody actually knows what will happen and when. After the DfT business (when nobody knew what was going to hit us, for a year or two, and even the best placed Govt sources were saying nothing, even to close friends) I believe anything. This business is full of people (I don't mean you) who say this and that is going to happen "soon" or "next year" or whatever, but in the end what actually happens is determined by the political masters at the top level, no matter what somebody lower down thinks of it. Just like happened with the DfT business: much of the CAA, much of the DfT, most UK (G-reg) flight training operations, all wanted to kick out N-reg. Did it happen? No. In retrospect it's obvious why not (massive political risk) but few people were certain of it.

I don't doubt for a moment that a proposal is being worked out right now. I happen to know that such a proposal was worked out a few years ago (in JAA of course) and was shelved under political pressure.

EASA, once they have fully taken over FCL, got up to speed on the daily bread and butter stuff, tackled all the existing projects that need to be done, only then they will be able to start on the really hot potatoes like this one.

They will do it OK, but only by offering a reasonable carrot like I outlined, and it won't be implemented next year.
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Old 29th Mar 2007, 15:09
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OK we are talking at cross purposes here. First the FAA test standards are the same as the UK IMC as far as tolerances are concerned. The JAA test standard is slightly tighter. I am not arguing the point on quality of test as we know the FAA test is very tough I am just making direct comparisons of the tolerances during test.

The N Reg debate is a seperate issue but the removing the IR barrier is on the road to EASA oversight on N Reg ops.

What I am discussing here is the JAA IR changes. Making a PPL/IR accessable in the same way as an FAA IR is now. I have a very direct involvement in this process and can assure you it is happening right now.

Taking the usual CAA bashing aside they are making a great effort to make the IR accessible to the PPL which is a fantastic safety initative. I happen to think that our regulator is being very proactive on this.
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Old 29th Mar 2007, 15:23
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Interesting. The JAA committee that was working on this in 2006 managed to shave about 25% off the ground school, allow IMCR training hours (max 15) towards the 50/55hr requirement, and that was as far as it got.

EASA is not doing FCL yet. We are still in JAA. EASA has taken over certification only.
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Old 29th Mar 2007, 16:21
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The 15h IMC course still DOES NOT count towards the IR and the latest efforts have shaved a good deal more off the exams than 25%. There will be fewer exams and the those that remain will be smaller. The whole objective it for enough knowledge relating specifically to IFR flight in CAS.

EASA are just around the corner on licensing and the CAA have a desire to have he IR amended before they take over. Trust me this is VERY good news for us.
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Old 29th Mar 2007, 17:00
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I'm not sure that I should intervene between Bose and IO, but I see this from a 3rd perspective.
All those years ago when I got my PPL, I discovered within a couple of months that whatever the forecast, it is irresponsible to use an aircraft to get about the UK without an instrument cabability. I got my IMCR soonest, and continue to have this view. This rating fulfills the need perfectly if there is no intention of airways flying. The test, repeated every 2 years, requires you to fly for more than an hour entirely on instruments, and navigate, fly holding patterns and two different approaches, and fly safely with the A/H and DI covered up, even when faced with recovery from unusual attitudes. Nearly all airports are in class D airspace, which allows the IMCR holder to use these facilities to the full when the runway RVR is more that 1800m. The safety, not accuracy, of flying on instruments is identical for IMCR and IR.

I now fly a permit very hot ship, and so never(?) fly in cloud. Last Monday I flew a lovely trip to Guernsey for lunch, without any relevent cloud for the whole trip. But in comfortably legal VFR the 'goldfish bowl' vis meant that it was impossible to fly at a sensible height for nearly all the trip both ways except entirely on instruments. Also, its a legal requirement to have an IMCR or IR to fly SVFR in the Class A Jersey zone in less that 10k vis (it was 6k on Mon, even though the last TAF and METAR I could get before departure was '9999'.

My point is that it would be dreadful if an 'easier' PPL/IR to enable airways flight lost us our invaluable IMCR.

And why, WHY, cannot an NPPL get an IMCR, even though both are solely UK facilities, if he(she) can pass the training and test? Is this yet another case of CAA b*****y mindedness? Let alone the requirement for a fully equipped permit aircraft to fly only VFR.
(Incidently, I have passed the ground exams for PPL/IR, but that was when it could be done by correspondence course)

MikeJ
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Old 29th Mar 2007, 18:10
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What real benefit is an easier to achieve IR when the vast majority of airfields have no IAP, or are we thinking self announcing GPS approaches at uncontrolled airfields are on the way as well? Little point being able to fly somewhere if you can't land at destination.

However if the number of IRs does suddenly increase and all that lovely Class A becomes available best you all get familiar with the world of CFMU, slots and flow control too
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Old 29th Mar 2007, 18:19
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The key benefit of a more accessible IR has got to be its use in European touring (legally ). The other big one will be not paying trust fees if you are not a US citizen!


I agree it will mean a lot of people getting familiar with CFMU but some how doubt that the enroute space at FL100 or the approaches to typical destinations are suddenly going to be full!
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Old 29th Mar 2007, 18:31
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For anyone leaving the UK to get to Europe the heavily regulated, in terms of flow and capacity, airspace of the SE of England will be a major barrier at the lower flight levels.

Will be interesting to see how it copes if more low and slow (no offence meant!) IRs come in to the system.
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Old 29th Mar 2007, 19:38
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I agree with MikeJ. The IMCR is great and very useful. if I was training somebody I care about to fly I'd make sure they can fly and navigate on instruments before letting them loose. The biggest obstacles to its utility w.r.t. weather are currency and a suitable plane.

are we thinking self announcing GPS approaches at uncontrolled airfields

This is very bold. In the USA you get a nearby controller to coordinate the approach to a non-towered field. Unfortunately, in the UK (and probably the rest of Europe) there is a billing system under which the airfield is going to get billed for that service. This would cost the likes of Wellesbourne / Stapleford / Welshpool etc 4 to 5 figures a year and they would not recover it from IFR traffic. Many of these places were happy to get rid of ATC and their ~ £70k salaries and the union rules. Biggin Hill gets a bill from NATS for Thames Radar, for example, but they have the movements.

Self announcement would work fine (after all, it's not illegal to fly a DIY IAP in Class G, non-radio!) but it is rather too imaginative for this "anally retentive safety" business.

So I haven't got a clue how this might be resolved.

However if the number of IRs does suddenly increase and all that lovely Class A becomes available best you all get familiar with the world of CFMU, slots and flow control too

IMHO the # of airways pilots will always be severely limited, by the cost of obtaining and operating a suitable plane. The entry level for a decent used IFR tourer is around £100,000. Look around your airfield; not many there... and many people with these are already flying IFR/airways.

And there aren't enough runways with IAPs in Europe to give GA sufficient utility to drive up the traffic to US densities.

As to density, you can fly airways say UK to Prague, FL150, and not hear another GA plane on the radio (I am assuming that N123XY getting a climb to FL200 is not an Arrow) . You almost certainly won't see another one. You may get visual with a few big jets, many miles away. And this is flying through some of Europe's busiest airspace: Brussels, Frankfurt. The claims of cluttered airspace just don't wash - at the FL100-180 levels where airways GA operates. That space is virtually empty.

CFMU is a pain but slots (for a low airways flight) are very rare.

The other big one will be not paying trust fees if you are not a US citizen!

Don't worry - you will spend any saving on EASA maintenance and certification. £2000 for the paperwork to install a different model of altimeter.

If Bose-X is right, the CAA (which cannot do this without JAA; I spoke to their head of licensing on this very topic last year) must have bludgeoned JAA into something pretty drastic, using the fear of what EASA are going to do, so JAA was forced to pre-empt EASA. We shall see.
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Old 29th Mar 2007, 19:43
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Trust me this is VERY good news for us.

I hope that I'm wrong, but I just cannot see it.

The IMCR works well in the UK with a relatively flat topography, a temperate maritime climate, and a NAA that doesn't mind that much if we kill ourselves.

As long as we stay out of CAS, and don't delay CAT that is.

Our Continental chums face greater vertical and climatological challenges. They didn't go for a EuroIMCR, and I can't see them going for an IR(lite).

But in any case only the naive will be sidetracked. The underlying objective of those who have paid for "the best government that money can buy" is:

No PPL's in A, B, or C.

I hope I am wrong.
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Old 29th Mar 2007, 21:34
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I am not aware that the incident or accident statistics suggests the IMCR is unsafe.

Weather conditions are arguable as challenging in the UK as in Europe. We have plenty of high terrain; I am not sure that because the Alps are higher it makes a great deal of difference. In some countries in Europe there are relatively more airports with an IAP with localiser. Moreover, accurate forecasting of the weather is more challenging in the UK than for much of Europe with the uncertainties of a climate so dominated by our maritime environment.

In Europe pilots are permitted and regularly fly above an overcast and so practically are close to having some of the practical advantages conferred by our IMCR in their “vanilla” PPL.

As IO says few aircraft are properly equipped to operate airways principally because their performance is marginal at these altitudes never mind that oxygen is essential.

The UK model should demonstrate that the IMCR confers many practical benefits on the GA pilot which would not demonstrably change if he were granted the same privileges as a pilot with an IR. Namely the ability to fly sectors in less than satisfactory VMC conditions without having to attempt to scud run or to climb to a safer altitude to transition across water or inhospitable terrain.

Those that believe if a simplified PPL IR were introduced it would result in droves of pilots flying airways sectors are simply wrong, and don’t understand the needs of the average GA pilot.

Those in Europe that believe the IMCR is unsafe are also wrong and often usually don’t understand the way UK pilots use an IMCR and also don’t understand that flying above an undercast in the UK is not possible without an IMCR.

If ever a Europe wide IMCR or PPL IR were introduced it actually wont make a lot of difference to many pilots. A few more might fly airways and the majority of those that do will have made a considerable commitment to their training and their aircraft to do so safely. Of these the vast majority will also be operating in the lower airways which are largely un-congested and currently little used. The vast majority will continue to fly relatively short sectors outside the airways system spending much of their time in VMC on top or in conditions of poor VMC but at least more safely being able to cope with changes in the weather and not being as restricted in the number of days they are able to fly.

If the benefits were not as clear as they are from the UK model and from America you might be forgiven for being cautious, but given that they are, if the regulators cant see the benefit and fail to do anything about it, they are just plain dumb.
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Old 30th Mar 2007, 06:52
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IMHO the reasons we have the IMCR whereas rest of Europe doesn't are these:

Many years ago, late 1960s, there were a few people in the CAA who had the balls and the foresight to propose it and carry it through. It could not happen today.

We have lots of Class G and (except a few bits in Scotland) no Class E.

The UK is now run on a "you use it, you pay for it" basis, and nobody wants to pay for proper ATS services (I mean enroute IFR, like the USA) in G. NATS won't pay, airlines won't pay, and UK GA pilots absolutely won't want to pay (especially as one doesn't need a service, really)

If the present free for all IFR in G was banned, somebody would have to fund a proper enroute IFR service. This is not going to happen, ever.

So, allowing pilots to fly freely in G, in/out of cloud, saves everybody money, doesn't do any harm, and sidesteps the need to face difficult issues.

It also usefully legalises the practice which is common all over the world, which is flying in IMC under VFR, and which (for > 2000kg) gains even greater impetus in Europe due to Eurocontrol IFR charges.

Currently, only about 10% of PPLs get the IMCR and the figure is falling. Yet, it isn't hard to do. IMHO, the numbers are being severely limited by (a) the entry cost to the "Class G IFR club": a decent plane and keeping current and (b) the lack of airfields with an IAP.

If the IMCR was pulled and replaced with some sort of reduced JAA/IR, the numbers of IFR capable PPLs would plummet.

The only real additional utility of an IR over an IMCR comes from being able to fly IFR abroad. (One could debate that to a degree - going from say Bournemouth to Aberdeen I would rather do it at FL150 than at 2400ft and dodging the hills etc but few pilots fly legs like that). And a tiny % of PPLs ever go abroad.

There would be extra people flying airways but as Fuji points out there will never be many of those. The entry cost to the "airways club" is even higher. You can fly in occassional IMC in G at low level in any old wreck with a GPS, but doing a 500nm airways flight at FL130 requires more performance and more kit.

If the IMCR is pulled, most people will just carry on flying VFR in IMC as required. What they won't be able to do is fly an IAP at the destination - unless they first do a DIY descent below cloud, some distance away, which is what European pilots generally do when doing this kind of thing. A very poor safety improvement!

I wonder how this "cut down IR" will be crippled. Anyone remembers the nutty FL100-max proposal from 2 years ago? That apparently came from the European flight training industry
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Old 30th Mar 2007, 07:56
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This is not a cut down IR for gods sake. IO I am sure you see an assassin hiding in every door way!!!

There is no suggestion that the IMCR is unsafe at all. But it is a unique anomaly in that it is a UK CAA only rating and like it or not we are now all part of one big happy Europe. The Europeans will not accept it so we have to look at the big picture and make the IR accessible to all.

The IMCR came about not because a group of people had balls it was because PPL's could fly in IMC with no training and were flying into things. The IMCR was a way of reducing this and over the years gained more functionality to the point where it became treated as almost a min IR. If it helps think of the new format of the IR as being a super IMC......

The point of this exercise is making the current IR more accessible. You all whittle on about how so much easier the FAA IR is to obtain and how you would do a JAA IR if it was accessible in the same way. This is exactly what we are trying to do with it. Reduce the theory exams, remove the 200 hrs minimum self study and remove the compulsory classroom consolidation.
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Old 30th Mar 2007, 09:44
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CJBoy, I have to have confessed to having the same thought for a moment when I got involved! I did the IR the "hard way" and so why should anyone else have it easy!!!! But that is exactly the reason why things needed to change. The people on the working group are very balanced, very experienced and very committed to make this work. The CAA are equally committed and are very much the driving force behind this.

I realise there is a great attachment to the IMCR but this is not the basis of the working groups remit, it is to make the IR accessible.

Sadly I do think that the IMCR will vanish when EASA take over the licensing and is why I feel such an imperative to make the IR accessible.

Those who think they don't want access to CAS A are really just trying to hang onto the IMCR, the sheer ease of airways flying has to be experienced to understand the huge benefit having an accessible IR over the IMCR.

LFAT on a sunny day, straight over the top of everything and into LFAT. Navigation is a breeze and radar service all the way. Contrary to belief the lower airways are not full of jet traffic.
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