PLEASE READ THIS AND HELP SAVE GA IN THE UK - Save the IMCR

[Justiciar]

"The great majority (43 out of 60, with 98 fatalities) took place in unfavourable weather, underlining the problems with lack of training, over-confidence, poor decision-making and pre-flight preparation.

All areas which are dealt-with by the IMC rating.

I suspect that this is the cause of the majority of accidents in most countries. I think we need to be careful in the way we draw conclusions. The report is interesting and highlights that more regulation does not equate to better safety. It points to the better fatality record of the less regulated ULM sector and also concludes that flights from within the strong club environment generally result in fewer accidents. The report is an argument for devolving downwards the responsibility for flight safety to 'local' organisations. It comments on the unsuitability of a regulatory system aimed at the professional pilot for regulating leisure flying.

The report is not unfortunately an endorsement of the IMCR ! It points out the relative similarity of accident rates in the US and UK. Whether that can be turned into an argument for an IMCR I doubt. It may be an argument for a more easily obtainable IR, but the report does not say so. It seems more to support the concept of a sports aviation licence (lightly regulated but with a safety and skills ethos being strongly promoted at local level), which may or may not be ICAO compliant and I would guess would be restricted to day VFR, but I bow to others with far more knowledge on this aspect than I have.

[IO540]

It may be an argument for a more easily obtainable IR

Since there is close to zero prospect of getting a significantly more easily attainable IR in Europe for some years, I would say that makes it a reasonable supporting case for the IMCR.

[Justiciar]

Yes, we just have to convince all the other 27+ countries in the EU to set up facilities to train for an IMCR. Is that not the real problem. No one but us has the skills base to do it or the interest in doing it. But, are we not some way off the point at which the IMCR goes? Plus, as I mentioned on another thread, what will happen to the French Mountain ratings, which are also national qualifications and will presumably go if all national ratings and licneces are swept away. They will be less than happy with unrestricted access to their altiports and glaciers.

[IO540]

Yes, the assumption that the choice is either (a) a euro-wide IMCR or (b) no IMCR at all anywhere, is fundamentally flawed and totally stupid.

But that is how Europe is working in this instance.

They would probably like to mandate that we all have greasy hair like the Italians, but that would be politically difficult

I do not have any idea whatsoever why national ratings cannot continue. It just seems a pointless piece of political ideology.

[S-Works]

The likelihood of a Euro IMCR is prop 0.1%. The airspace structure in Europe does not support the IMCR type flying like the UK. French Class D airways for example, germany has no concept of IFR flight outside CAS etc etc.

If you are going to continue with this crusade you have to actually decide what exactly you want and stick to your guns. You also REALLY need to get an understanding of the rule making process rather than just shooting from the hip.

As IO points out there is very little sense in pointless rule making, yet the Europeans are fond of signing up to pointless stuff. Look at Galileo.....

[Justiciar]

If you are going to continue with this crusade you have to actually decide what exactly you want and stick to your guns.

Agreed. Surely the objective should be the maintenance of national ratings for use in that country's airspace? There seems to be a dawning recognition even in the EU that people are being turned off by the top-down regulatory approach and that devolution of regulation and responsibility is the way forward (as mentioned in the French report, above). The one size fits all approach no more suits us than it would the French with their mountain ratings and there may be other countries who also have their own licneces and ratings which they are equally attached to.

[S-Works]

What you mean back out of the agreements that we have already signed to hand over regulation to Europe? Keep the current system of 'common' standards with national control?

[rustle]

If only we'd known this was coming

[S-Works]

We would have had the opportunity to respond and make representation, even forming a working group to try and make the IR more available in the event of the loss of the IMCR.....

[dublinpilot]

I think what Justiciar is suggesting is that national ratings would stay under EASA, but only be valid in one particular country.

For example, the IMC rating would simply be an EASA rating, which could be attached to any EASA licence issued by any EASA country, but would only offer privlidges within UK Airspace. I could add an IMC rating to my Irish issued EASA licence, but I could only exercise it within UK FIR's.

Likewise a UK issued EASA licence could add an Altiport rating to it, but again it would only have privlidges within French airspace.

Specific 'local' ratings for on an EASA licence....seems to make sense.

dp

[S-Works]

dp, Thats exactly what we had under JAA (which worked fine in my mind) but under EASA we do not have this option. Under JAA the national authorities were responsible for licencing with there own ANO etc but fitting into the JAA framework.

Under EASA we now have a European aviation authority that will have a european ANO and issue a European licence. It is because EASA are the licencing authority now and they have declared there will be no national differences that we have the issue.

We have signed our rights away completely.

[englishal]

The Norwegians have it right.....Get all the benefits of Europe while remaining outside of the EU...

[rustle]

Nice fjords, too.

[Pilot-H]

The report is not unfortunately an endorsement of the IMCR ! It points out the relative similarity of accident rates in the US and UK. Whether that can be turned into an argument for an IMCR I doubt. It may be an argument for a more easily obtainable IR, but the report does not say so.

If you read the report fully, you will see that it does indeed argue for a more easily obtainable IR, which is about all they can do, hamstrung as they are with airspace and rules which could not permit an IMC rating.

It also cites the British NPPL as a good thing (in the context of a sidestep from JAR-FCL) Given these points, and the fact that their fatal accident rate is twice as bad as ours, it is an endorsement (albeit tacit) of the IMC rating, and shows where we will be without it.

A few relevant parts loosely translated:

"JAR - FCL: A training system poorly suited to private pilots
The JAR-FCL training system is concieved as a professional qualification structure, because it aims to train pilots from ab-initio and bring them to a professional level, (CPL, or ATPL) whether by the integrated route or the modular route. In this second case, the training for a PPL constitutes the first step on the route to becoming a professional. The training programme is therefore conceived and implemented with this view, without being particularly adapted to pilots who consider the PPL as their goal...."

"Certain countries, such the United Kingdom, becoming aware of limits of JAR-FCL decided to impliment a National Private Pilot Licence, whose privileges, naturally, can be exercised only within UK airspace.

It is in this framework that we look towards private IFR flying: even though the JAR-FCL Instrument Rating concerns probably a very limited number of Private Pilots, due to the implicit requirements and costs (maintaining an appropriate level of currency requires regular practice on relatively complex aircraft), it doesn't make it less true that the qualification itself is percieved as very difficult to obtain. The major obstacle cited, with good cause, is the theoretical training, the requirements for which appear dis-roportionate to real need.
Henceforth, nothing should oppose the implementation of an Instrument Rating theory appropriate to the PPL"

[Fuji Abound]

.. .. .. and the answer is,


we are going to try and get a national difference agreed.


On an aside issue, I was pondering how EASA intends to enforce its new ANO. Presumably this is to be left to the respective national authorities (who will effectively be EASA satellite offices). For example, a pilot is accused of low flying - will this still be prosecuted through the local magistrates court?

On another side issue what will happen to the special exemption permitting pilots to operate in class A without an IR for the purpose of parachuting, glider launching or high performance civilianised jets? Are these to be national differences, rights abolished or exceptions?

[S-Works]

Good luck. I hope you succeed. Who will you be approaching to get this exemption?

I am curious about the Class A airspace exemption you mention, please can you point me in the direction of it?

Yes you are quite right about prosecutions etc, they will be left to the local CAA office with European visibility.

[Justiciar]

f you read the report fully, you will see that it does indeed argue for a more easily obtainable IR, which is about all they can do, hamstrung as they are with airspace and rules which could not permit an IMC rating.

Yes, you are right - that is the trouble with speed reading a 62 page document in French .

It mentions the content of the extensive theoretical element as not being suited or necessary to real conditions. It also suggests that a reduced theoretical knowledge could be devolved down and be administered by local organisations.

All this supports what I believe bose-x and others have been arguing for, a review of the training requirements of the IR across the EU which only incorporates those elements necessary for the IR and places other airline orientated parts in their proper place, i.e. in the CPL or ATPL exams. There have already been some changes to the theory element in JAR-FCL 1 but these await implementation by the CAA (bose-x will shoot me down if I am wrong on this).

We have to fight for what is achievable. Reading what has been said it seems that national ratings will go - we should not be wasting time arguing for something which is not achievable in the current legal structure (and I doubt the UK will or can withdraw from EASA). Can any country file national differences as they can under ICAO? I don't know the answer nor what would be involved in doing this.

What we seem to have is support from other countries, e.g. France, for the idea of devolving down the implementation of EASA licensing requirements and training. We could therefore see exams administered at local level as in the PPL training. We already have a split in the practical training requirements. Perhaps we should be building on this.

[Fuji Abound]

We have to fight for what is achievable. Reading what has been said it seems that national ratings will go - we should not be wasting time arguing for something which is not achievable in the current legal structure

I think there is a significant danger in that line of argument.

It is simply that the IMCR will go as part of early implementation of legislation but will not be "replaced" in a hurry, or at all, with a "simplified" IR.

History would seem to predicate that there is not an appetite for a simplified IR.

Personally, I think this would be a very wise alternative and I wish Bose and AOPA very well in their quest.

EASA has a mission statement:

"Our mission is to promote the highest common standards of safety and environmental protection in civil aviation."

The abolition of the IMCR hardly promotes safety, especially if it is not replaced with an alternative. Moreover, arguable for those with an IMCR already adequate for their purpose withdrawing their existing rights without offering an immediate alternative is contrary to EASAs mission.

[S-Works]

This is where you miss the point entirely. In the opinion of the rule makers you already have an option for flight in IMC it is the IR. It is the only option that the rest of Europe have. So as far as they are concerned this is a non issue. It is only because you have the IMCR that is so easy to obtain that the IR looks so difficult and while I completely agree the accessibility is not that great which is the fault of our own CAA to a large extent, the IR is not difficult to do.

Like I said I am just pragmatic. However I really do wish you the best and will watch with great interest your progress. Mostly to work out where to insert the 'I told you so's'........

[Justiciar]

I

think there is a significant danger in that line of argument.

It is simply that the IMCR will go as part of early implementation of legislation

I am afraid that those two sentences defeat your own argument. There will be, under EASA no legal basis for the preservation of national licences and ratings. It is not a question of arguing for the use of a power to allow the continuation of national licneces: there is no such power, as I understand it. The only way of doing that would be by the UK withdrawing from EASA. I doubt that is possible or likely.

Certainly, changes will take some time. How long have the changes to FCL 1 taken? Several years, I suspect. But then the CAA is not noticable by the speed of making changes to legislation.