EASA? What a joke!

[DFC]

In order to demonstrate an effective counter argument in this case, I do not need to quote stats or facts. All I need to do is simply plant seeds of doubt and hit on a few fundamental areas that will not be seen as reasonable by those who will sign the dotted line. Those people will be thinking of the impact on their pilot population or more importantly it's impact on their career if an IMC rating holder has an accident in their home country.

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.

I love the quote - "there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record" (Source AOPA)

Well I would not call an aircraft without full IFR instrumentation and radio equipment serviceable for IFR flight and more importantly...........a multi engine aircraft with one engine failed is most definitely not serviceable.

Similarly, I would not say that unsing less than the IMC notified minima is legal.

That AOPA statement is worth just as much as saying pilots who don't fly never have accidents.

-----------

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.

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.

Again - the IR is a PPL level qualification that you get credit for should you apply for a CPL.

Regards,

DFC

[Fuji Abound]

Again - the IR is a PPL level qualification that you get credit for should you apply for a CPL.

I agree.

All I need to do is simply plant seeds of doubt and hit on a few fundamental areas that will not be seen as reasonable by those who will sign the dotted line.

I also agree.

An effective campaign must eventually focus on the facts.

Of course if ultimately the decision makers are not prepared to determine the issue on the facts then we are all lost!

Equally, I would not want to be one of those who had put forward a load of spurious nonesense purely for sake of destroying a worthwhile initiative.

[Keef]

Justiciar: thank you for some sensible words in an otherwise very noisy bar room. I hope the EASA and NAA folks aren't reading this lot.

There's too much argument about what individuals think, or see as potential risks, without facts to support. There are far too many teddy bears littering the floor round the prams. If the fighting tigers are really supposed to be representing someone, I despair about the process that "appointed" them.

Those who don't want to hold an IMCR aren't forced to. Those who do hold an IMCR haven't been driving into terrain with monotonous regularity - on the contrary. So it seems to work in the UK.

I have an FAA IR, but unless the aircraft has the magic letter N painted on the side, I can't use it in Europe. How sensible is that? In the UK, I can fly in IMC in my G-reg aircraft, but once I reach mid-Channel I suddenly become incapable of IMC flight. How sensible is that?

I never did get the hang of politics.

[S-Works]

EASA will probably create two "private" pilots licenses - so the IMCr will have to be attached to one or the other.

So to ask the question yet again..... Which of these is your campaign planning to attach the IMCR to?

[rustle]

Originally Posted by Fuji Abound

...I would not want to be one of those who had put forward a load of spurious nonesense purely for sake of destroying a worthwhile initiative.

So which bits are spurious nonsense then?

Also, could you please link to these reports you keep mentioning and quoting from - if they are authoritative I'd like to read the whole thing rather than just snippets. Thanks.

[Fuji Abound]

So to ask the question yet again..... Which of these is your campaign planning to attach the IMCR to?

Please appreciate that I personally have come to this very late in the day.

As I have said on numerous occasions, you and others did warn us that if we did nothing we would only have ourselves to blame - so I decided to try and do something. Foolhardy - perhaps, misdirected - maybe, but I am trying and it is taking a great deal of time (and I dont mean the posts on PPRuNe - there is a fair amount going on that is not yet evident).

Without mentioning any other parties I did feel not enough was being done by any of the representative bodies. If I had, I would have left it to them.

So that was the conundrum. The atmosphere appeared to be one of - the battle has already been lost, so coming in behind with the cavalry was no bad thing.

I appreciate your questions, but you must understand I dont have all the answers yet for the reasons I have said. However I am in discussion with those who I think can answer some of the questions and understand far better that I what is possible and technically the best way of achieving this. I am sure you are well aware of some of what is taking place and the discusions that are already underway.

Rightly or wrongly, I beleive the key at the moment is for there to be a full, sensible and mature debate about the issues, which sadly has not taken place before, an assessment of the support for retaining the rating, whilst developing alongside the best way of bringing to fruition what the majority of pilots believe is an important initiative.

I would hope we can all work together constructively, even if some may believe there are good reasons for not retaining the IMCr.

Does that answer your questions?

[S-Works]

No it does not. However you would have made a fine politician with your ability to evade answering a direct question.

Without fighting with you I am asking for a very simple statement from you as to what your pitch is.

What form will you want to IMCR to take in the future an what licence do you see it being attached to.

Please state clearly what your safety case is, how you see the IMCR being taught and maintained.

If you can answer those simple questions you campaign will hold more credibility. At the moment you are making a lot of noise and evading direct questions. It strikes me that every time the subject gets to hot you go and attack others to divert attention.

So please just answer the question.

[rustle]

Fuji, can you update us with what the Popular Flying Association aka Light Aircraft Association are doing to assist in the "save the IMC" cause?

We've heard lots about AOPA, so what are the PFA/LAA doing about it? (There must be pilots within PFA/LAA who also fly IFR capable aircraft)

Thanks in advance.

[BEagle]

Some Truths!!

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...

[Justiciar]

So please just answer the question.

I will answer it. There are two scenarios:

1. 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
2. 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.

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.

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.

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.

[Contacttower]

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.

All those attacking Fuji are being slightly unfair I think, we don't know exactly what we are fighting yet...so a set in stone battle plan is perhaps not such a good idea...we need to be careful and react with common sense.

[rustle]

Originally Posted by Contacttower

...we need to be careful and react with common sense.

A bit friggen late for that, don't you think?

[Contacttower]

A bit friggen late for that, don't you think?

And do you have a better idea?

[rustle]

Well one better idea would be to agree what it is you want.

Justiciar's post, whilst interesting, missed option 3 (at least) which is a straightforward rubber stamping of everything EASA wants, including the abolition of national licenses and ratings: On that happening you really need to get your ducks in a row before launching petitions (what are you asking the PM to do) and having several threads running in the public domain which, in and of themselves, are so full of disinformation as to be next to useless and lacking credibility.

Another better idea would be to have a full understanding of both current and proposed privileges of a rating - even the bits that don't fit your argument as nicely as others.

Another better idea might be knowing how to answer questions without going on the defensive immediately, nor telling people they have missed the point.

Maybe, as a fourth idea, these several threads should be allowed to die until some or all of my other better ideas can be accommodated

[Justiciar]

missed option 3 (at least)

This was not an option for preserving some form of IMCR - hence is not an option at all though it is a distinctly possible outcome.

[S-Works]

All those attacking Fuji are being slightly unfair I think, we don't know exactly what we are fighting yet...so a set in stone battle plan is perhaps not such a good idea...we need to be careful and react with common sense.

Oh for Gods sake, we know exactly what we are fighting and so would Fuji if he had bothered to do any actual research on the situation.

As we have know what we are fighting for a long time it would be rather helpful if he made a statement of exactly what he is saving and why and how he would like to see it moved forward. It does not have to be set in stone but at the moment it is not even in quick sand.

We are also still waiting on his comments on the PFA efforts that rustle asked for several posts ago.

I realise that it may seem that I am being provocative, bit all I really want is him to demonstrate he has a real grasp of the situation and a plan to move forward with a resolution. At the moment all I see is hot air and abuse.

[Contacttower]

Oh for Gods sake, we know exactly what we are fighting and so would Fuji if he had bothered to do any actual research on the situation.

Well yes and no...I know you have been quite rightly highlighting this for a long time but at the same time as Justiciar posted there is still more than one possible outcome to what EASA may decide.

Perhaps we should let this thread die now....sorry for starting it in the first place.

[Fuji Abound]

ContactTower.

The worst thing would be to let this go away.

The debate has to develop. The approach and views will solidify.

There are always going to be different agendas at work - that is usually a good thing and from all the emails I have had (over 20 just today) every one has been hugely supportive.

The petition now has 350 names on it including for example

Al Walker - CFI RAF Halton Aero Club

Thank you Mr Walker.

Those in support need to stay with it for the long haul.

I have been told today that this very campaign has been very positively noticed - so those that would tell you otherwise are simply wrong.

Brilliant.

[S-Works]

I have had more than 40 emails today asking if you are ever going to stop blowing hot air and self congratulating and actually set out your campaign.

Brilliant.

[S-Works]

Wow, huge......

Just another 10 or 12 thousand to go for majority support. Keep up the good work.

Not to mention the fact that the petition is clearly fraudulent with a significant number of names having been added to it fraudulently or falsely including my own.

How do you expect to be treat seriously......