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

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

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Old 9th Dec 2007, 21:30
  #141 (permalink)  
 
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You truly are a crackpot.....

Nobody has ever suggested it is left to AOPA or anyone else for that matter.

You are perfectly at liberty to run your own campaign. We understand perfectly that you think AOPA have done a bad job, you have made it clear by using these forums as your personal anti AOPA soapbox.

You know what, I don't actually care anymore!

mad as a hatter.
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Old 9th Dec 2007, 21:37
  #142 (permalink)  
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Fair enough .. .. ..

.. .. .. lets just agree to disagree. It will make things a great deal more peaceful.

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Old 10th Dec 2007, 12:11
  #143 (permalink)  
 
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Originally Posted by englishal
What is this, the new Timothy / Gerard side kick show
Who?
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Old 11th Dec 2007, 20:27
  #144 (permalink)  
 
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Well, I saw the thread title, and excited by an opportunity to be informed, engaged, and motivated by some intelligent, active campaigners to save (my) IMCr, I have just read through all 143 posts (sorry, I was in Russia last week).

I have noted how the number of enthusiasts offering help in the first couple of pages has dwindled to practically zero.

My current status:-
Your joint efforts (and I mean ALL of you) leave most of my remaining hair torn out and on the floor.
I have yet to see benefit in being involved with ANY of you.
I await with interest your(plural) decision to use your energies constructively.

Yours
SD

PS yes, I have been aware of this issue for some time, yes I have seen a couple of recent low key aopa items on the subject, no I have not yet been persuaded to invest my 72 quid, no I do not have an axe to grind.
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Old 11th Dec 2007, 21:25
  #145 (permalink)  
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Sunday Driver

It is indeed a shame and I regret the way this thread has deteriorated. I am sorry. However you should not under estimate the strenght of support.

Firsly, in case you did not follow the thread you should visit the petition and note the number of pilots already signed up. This has occured with no publicity other than that which has taken place on PPRuNe.

Secondly, there are people who have a different agenda, or one that is less than clear. It is in the nature of debates of this sort that they will vent their views. This forms an important part of the debate. By definition they are likely to be as vociferous as those in favour. However, I can assure you by the number of emails and posts I have had that there are many, who although they have not posted, have closely followed and support this campaign.

Thirdly, there are already a few of us who are working together to increase the profile of this issue. There will very shortly be a dedicated web site. There is already a petition. There will be far wider representation.

Forthly, consider this as a starter for ten posted else where.

"Here are some observations to think about:

Controlled flight into terrain (CFIT) accounted for 30% of all fatalities between 1995 and 2004. There were 3,000 fatalities in consequence. (Source: CAA SRG 2006). In a similar length of time (1985 to 1994) CFIT and loss of control in IMC involving aircraft with a MTOW of 5,700 kg or less accounted for 28.5% of all accidents. (Source CAP 887 CAA Safety Regulation Group).

The SRG noted as follows:

“Typically, the CFIT accident involved the more mature and experienced pilot who, despite his experience, seemed to be oblivious to the dangers of continuing the flight into deteriorating weather conditions.”

The reports observes

“Usually, training for the Private Pilot’s Licence (PPL) takes place in good weather and with the advent of more candidates training for the PPL overseas, this trend is likely to increase”

and concludes

“It was considered that PPL training should be subjected to a greater level of CAA oversight to ensure that the best information is made available to candidates particularly in the areas of weather appreciation, calculation of safety altitude, flight planning and diversion techniques.”

The IMCr training syllabus incorporates all of the components of the SRG’s conclusion.

Loss of control in IMC was identified as the fourth most common accident type in the same report. The report states

"Three quarters of the pilots involved were attempting to fly in IMC when not qualified to do so."

IMCr training would have enabled the majoity of these pilots to avoid these accidents."

This is just part of the reason why preserving the IMCr is so important.

As has been pointed out on here on numerous occasions the JAA IR is not a viable alternative for most private pilots. The FAA IR is an attractive alternative but the concerns about its use in Europe continue unabated.

Moreover an IR extends the priviliges of an IMCr beyond that which many private pilots require.

If you believe in flight safety and take on board the statistics and findings above I think we have a duty to support this initiative.

I commend it to you.

Please let us know your views?
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Old 11th Dec 2007, 22:09
  #146 (permalink)  
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From another palce

"Have just been watching the (live) broadcast this evening from Strasbourg of the European Parliament reading / debate on the extension of EASA’s scope to Licensing, Operations and Third Country (i.e. non EU) Aircraft.
Several MEPs made reference to the importance of light aviation and the SME sector, the impact of EASA of costs particularly on maintenance (with a UK example quoted of a 60% increase). But most significant was UK MEP Philip Bradbourne’s speech which criticised EASA for its inefficiencies and failings, and the burden of red tape. “Not yet fit for purpose” he said, opposing the extension of EASA’s scope.

UK MEP Timothy Kirkhope (he is a private pilot) said EASA is incompetent, with delays in procedures and other difficulties and not yet fit for purpose. He said the UK costs were already high because of the CAA’s requirement to recover full cost. He referred particularly to the impact of EASA on private pilots and in particular the threat to UK pilots of possible withdrawal of the IMCR. He quoted Flyer Magazine, then referred to the UK weather which required the use of the IMCR . “Scrapping the ICR would be disastrous.” He asked the Commissioner (Jaques Barrot) to take a close look at this.
Barrot responded that he would be “at Mr Kirkhope’s disposal” to look at this.

The full Parliament vote on the 2nd reading is tomorrow.

I think the session was recorded and should be available at:

http://www.europarl.europa.eu/wps-eu...net/faces/vod/"
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Old 12th Dec 2007, 12:32
  #147 (permalink)  
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I thought this was an interesting comment from elsewhere worth repeating from a very well respected and very experienced avaition journalist:

It's disgraceful/shameful that the IMC rating was allowed to be led quietly and meekly to slaughter through a process not fit for purpose for these types of ratings. If the reps spotted this problem with the process, why weren't they alerting everyone to it months ago and objecting to it? Are they under self-agreed gagging orders or didn't they notice ?

2) Some of the other reps in the meeting 'deciding our IMC future' use VERY different classifications for their airspace, and their 'picture' of what really happens when pilots are let loose mixing it with commercials in IMC is not something you can break down that easily. I'd love to see the content of the UK pitch and perhaps even more interesting how long they had to get the message across. I suspect I will be shocked if I ever find out!
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Old 12th Dec 2007, 15:09
  #148 (permalink)  
 
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I have noted how the number of enthusiasts offering help in the first couple of pages has dwindled to practically zero.
I agree - how this has remained a sticky is beyond me. We now have two threads rehearsing the same arguments and trading the same insults. This thread should be for informed debate and nothing more.

Has anyone read the EASA literature on the proposed amendments and new regulations? I may be wrong (usually am) but some of the points to emerge seem to be:
  • Lightening of the Part M regulations for light aircraft maintenance (inherited from JAA)
  • More industry involvement in maintenance oversight and regulation at the expense of the local CAA
  • Proposal of a light aircraft pilot's licence (LAPL) with less onerous and less bureaucratic training requirements
  • The liklihood of additional ratings (and some form of instrument flying rating is mentioned in the consultation)
I know it is fashionable to knock anything European ( and God knows, there is enough to knock) but it seems to me that the movement at EASA is in the right direction. They have inherited onerous regulations from the JAA which they appear to be addressing; the legislation giving them power over flight crew licensing is only now before the European Parliament and some of the changes they would like to make involve a change to the basic Regulation, i.e. it has the go back before the European Parliament. This takes time in Europe just as such changes would take time in the UK, the US or any other country.

Interestingly, a number of proposed changes are in the face of almost universal opposition from a number of national CAAs - perhaps because it involves a devolution of control and responsibility away from them in favour of national associations and industry bodies. Perhaps that has something to do with the hatchet job being performed on them by our own CAA. Lets face it, the boys at Gatwick are not exactly the most progressive bunch on the planet in certain areas.

The creation of a pan European Pilot's licence has alot to recommend it. It may in fact grant greater privileges than the current PPL (remember that the ICAO privileges for VFR flight are greater than the UK currently allows, e.g. VFR on top). It may well be that the loss of the IMCR will be a penalty of this common approach to licensing. I do wonder if this will be short term, until regulations are introduced provising for additional ratings to be added to the LAPL.
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Old 12th Dec 2007, 16:06
  #149 (permalink)  
 
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One thing I am curious about is what will happen to instrument training in the UK.

It's obvious almost nobody will do the "EASA IR" and anyway the vast majority of PPL schools cannot train the IR.

Presumably it will be possible to legally teach instrument flight but why would anybody bother if they don't get any privileges? It's like the various AOPA add-on module proposals from years ago - they fell flat because it was obvious nobody would do them in the absence of real benefits. Few PPLs train for the sake of it.

And if you can't log the lessons towards something, there is no benefit in going with an instructor. It will be just as good, in fact probably a lot better, to go up with an experienced private pilot and drill holes in clouds around some VOR etc. Lot cheaper too.

On the practical side, anybody instrument capable will still be able to fly in IMC under VFR, as people do all over the world. But, only with an OCAS departure, or only enroute. No instrument approaches in actual IMC, short of a mayday.

If all this comes about, things will get interesting...

Incidentally, Bose, the reason I did not believe the IMCR would end is because I never thought the VFR-only lobby would be able to "arrange" the committee votes to strip the LAPL of the IFR option, against EASA's express previous wishes. But they did it - a very clever move probably organised beforehand.

(posted on both threads)

Justiciar - the LAPL appears to have been stripped of the IFR add-on option.
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Old 12th Dec 2007, 16:14
  #150 (permalink)  
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Justicar


Some very interesting comments.

I think the key issue is that in the UK we need to preserve some form of accessible instrument rating.

It is easy to forget in the detail of the debate that there is no real alternative.

As matters stand the European IR has proved universally unpopular. That is not because of the existance of the IMCr in the UK either. There is almost zero uptake in the whole of Europe. The reasons for this are well rehearsed and there is nothing on the horizon to suggest this will change.

The choice is stark.

Accept that Europe will become all but devoid of private instrument flying, that many will simply break the law and risk their own lives or the lives of others, or fight to preserve and extend a very worth while rating.

Of course we could hope that with the new EASA license will come priviliges in the future that will address this issue - however it is usually far more diffiucult to achieve those changes down the road and the history in aviation of doing so is dreadful.

Finally, forgive me, but I dont think your comment about the offers of help having dried up is entirely correct. In the nature of things like this there is an initial flurry of interest and activity, then a hard look at the issues and perhaps a slower and wider appreciation of the consequences.

We are a nation in which it takes time for people to become sufficiently determined to address any restriction of their "rights", but I hope we are determined.
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Old 12th Dec 2007, 17:08
  #151 (permalink)  
 
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As matters stand the European IR has proved universally unpopular.

Fuji,

I'm not sure that that is the full story. It's certainly the case that you don't have the rest of Europe getting worked up about this issue, but that's most likely because they aren't loosing anything. Therefore the issue doesn't get much 'airtime'. The local CAA's may not want the non IR, IFR flights, so are happy with the lack of 'airtime'.

However I suspect if the other European PILOTS (not the CAA's) were aware of the potential benefits, that they would be interested. I certainly have looked on the UK IMC rating with envy over the years. I asked the IAA would they consider something similar about two years ago, and was told no.

When you get everything up and running, if there is any spare capacity, it might be worth your while trying to make contact with other European pilot organisations (and publications to spread the word). If they were informed about the potential benefits, they may become useful allies, and be able to place pressure on their own representatives.

dp
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Old 12th Dec 2007, 17:27
  #152 (permalink)  
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Dublinpilot

It is intersting that I have had five emails from European pilots with regards the IMCr.

Of those three expressed the view that it was a dangerous rating. None of these were instrument rated.

I explained to them the advantages, the training involved and the way pilots in the UK used the rating. I believe I did so in a non biased way.

I can candidly say that they were amazed. They had no idea what was really involved and two of the three went on to say there was a fair amount of disinformation that they had heard about the rating.

In every case they have become strong supporters and would love to see the rating introduced in their country.

I think you might include yourself in those who would support their view?
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Old 12th Dec 2007, 17:34
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Absolutely. I'd love to see the rating adopted across Europe. I had tried to find out who the Irish representative is on the EASA working group so I could lobby them. Unfortunately, we don't have a representative on the committee!

I'll see about contacting our MEPs

dp
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Old 13th Dec 2007, 15:20
  #154 (permalink)  
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Some very useful contributions to this debate:

1. EASA will not permit the CAA to issue any EASA licences or ratings with further 'UK airspace only' restrictions on them.

The reason I asked for information on this was that I saw a possibility of the CAA issuing (on behalf of EASA) EASA-FCL IRs restricted to existing IMCR privileges only and in UK airspace only. A simple way out of the currently looming mess - but not permitted under EASA regulations....

2. The only way to retain the IMCR is to convince the other EU states of its value. Otherwise it will be swept away.

I have seen a draft RIA (EASA, of course) which seems to think that the only way forward is to let UK IMCR holders 'convert' their IMCRs into EASA FCL IRs by an additional 5 hours training and testing and a 'theoretical examination'. However, this so-called Regulatory Impact Assessment has not given any cost estimates for this process, neither has it assessed the loss of business for those RFs currently teaching for the IMCR. It is a totally flawed draft RIA in every respect and is the product not of any GA organisations.

Personally I consider EASA fundamentally unfit for purpose - its whole rationale must be questioned by MEPs and this whole lunacy delayed.

When the NPA comes out, you must comment. But do NOT cut and paste the comments of others. Every single comment must be answered individually, so the more comments the better as this will slow everything down considerably...
Beagle

Quote:
So please just answer the question.

I will answer it. There are two scenarios:

The European Parliament does not vote in that part of the amendment designed to give EASA exclusive competence in Flight Crew Licensing = national authorities retaining competence; or
They do but do not rubber stamp the draft regulations put before them, arrived at by what sounds increasingly like a cosy stitch-up, and instead provide a power for a for IFR ratings to be added to the euro sports licence (which I believe is what EASA originally envisaged).
In the first scenario the IMCR is retained; in the second a euro version will emerge. That may not be for some years, but the power will exist.

Of course the phasing of any EASA take over of licensing is an aspect we haven't really considered. It is possible that any amended Regulation will have a longer transition time that is envisaged.


Quote:
If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.


No: you rely upon the evidence which is available at any particular point. Forget figures for a moment and tell us what anecdotal evidence there is thet pilots exercising the priviliges of the IMCR are causing a danger. I am unaware of any such evidence. The difference as regards Europe is that whilst they may not have experience themselves there is substantial evidence from the UK of how such a rating works in practice. Europe should therefore be in a better position to judge than the UK was when the rating was introduced. Of course it may not be desireable to transfer the concept wholesale. There are airspace differences, for example, and there may be valid issues on the degree of training. The may be a case for splitting the privileges into a number of different qualifications or sign offs, as I believe they do with approaches in Australia.

What we seem to have from Europe is a knee jerk reaction which fails to consider how such a rating would work in practice, how it works in the UK and whether it may be desirable as a means of increasing safety by enhancing pilot skills.


Quote:
All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.

So why do the theoretical knowledge requirements contain so much which is wholy irrelevant to PPLs? Why is there no credit for instrument flying already done, as is allowed by Annex 1 of ICAO (and is recognised in the FAA IR training)? I believe that recent proposals for modifying the knowledge requirements are on hold and may not see the light of day for some time, if at all.


Quote:
The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.

Am I alone in not understanding the relevance this comment in relation to the issues Credit across the various aspects of the training is to be welcomed. However the existing system is cumbersome: for example, anyone initially getting a CPL or an IR and who later wants to go the ATPL route has to redo exams by sitting the full set of ATPLs. Why we do not have a progressive system of training and exams like the US is beyond me.
Justiciar
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Old 14th Dec 2007, 11:51
  #155 (permalink)  
 
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Incidentally, the so-called 'lighter regulation' EASA now proposes for the LAPL includes a mandatory proficiency check every 4 years.....

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Old 14th Dec 2007, 13:41
  #156 (permalink)  
 
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I don't know if this has been posted elsewhere (the topic is spread across many threads and it's quite unwieldy) but I received this in response to an email Isent on the subject to the MEP in my area (rather more effective I hope than signing a petition, though I'll happily do that too)

It appears there is at least one MEP (Conservative Spokesman on Transport) who will be personally affected by this, which is a good sign....

"Pilot licenses under threat*from the new EU aviation safety agency

Strasbourg, 13th December 2007 --*Timothy Kirkhope MEP, Conservative Transport Spokesman in the European Parliament, warned that pilots of small planes and aircraft training schools*might face burdensome red tape if bad weather flying is*regulated by the new European Aviation Security Agency.

The Instrument Meteorological Conditions Rating (IMC) which allows UK pilots to fly in unfavourable weather conditions is now under threat from new powers given to the European Aviation Safety Agency - which is slowly replacing the current national regulator in the UK, the CAA. According to Mr Kirkhope the impact could be*serious*for the small aircraft industry.

He said: "The IMC Rating was designed for peculiarly British weather conditions. If the EU scraps it the British light aviation industry*could* be hit hard. It would mean that thousands of pilots*might either*have their flying*licence rating revoked or have to spend a lot of money and time obtaining a higher European rating.**

Mr Kirkhope, who*himself holds a pilot's license*and IMC rating,*addressed Transport Commissioner Jacques Barrot and said: "Please Commissioner, reassure me and other pilots about this. EASA's performance has been unacceptable and I am afraid it is not yet fit for purpose."*

Mr Kirkhope is now seeking an early meeting with Commissioner Barrot to discuss the issue*and to*try to find a solution to the problems. "*
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Old 14th Dec 2007, 14:24
  #157 (permalink)  
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Mr Kirkhope is now seeking an early meeting with Commissioner Barrot to discuss the issue*and to*try to find a solution to the problems
He has his meeting.
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Old 15th Dec 2007, 21:22
  #158 (permalink)  
 
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http://petitions.pm.gov.uk/IMC-Rating/
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Old 21st Dec 2007, 22:27
  #159 (permalink)  
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Well over 600 signatures now and still running at nearly 50 a day.

Please, if you have not done so, give your support.

and if you have, tell as many others about it as you can.
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Old 30th Dec 2007, 22:13
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The first I read of this was in Flyer this month - and yeah - this would put an end to about 80% of my flying. Will add signature and write to MP....
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