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EASA? What a joke!

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Old 13th December 2007 | 20:10
  #221 (permalink)  
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From: Winchester
The worst thing would be to let this go away.
Sorry Fuji that's not what I meant...at all!

What I should have said is that this particular thread is not getting far, has exhausted its original title and people who have something serious and relevant to say should contribute on your sticky.
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Old 14th December 2007 | 08:55
  #222 (permalink)  
 
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Trying to be neutral and not commenting on individuals' positions here is quite difficult.

Bose-x: I do get the feeling that you have lost sight of the process, as perhaps have we all. There is a political dimension here. Whatever the machinations of the committees and the manoevering to produce a desired result it is the politicians, the MEPs, who now have their say. Yes, they may well rubber stamp what you guys have put forward from committee as a "good idea", but they may not. We are now in the arena of good old fashioned lobbying, and this is where petitions, letters to MEPs and the general raising of public awareness can have a benefit.

When this thread started I was under the impression that the changes to EASA's remit were a done deal; in fact that was the impression you and others conveyed, to me at least. That is far from the case. There is an increasing dissatisfaction with the way Europe does things and imposes cost and regulation on individual groups and countries. The worm is beginning to turn.
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Old 14th December 2007 | 09:39
  #223 (permalink)  
 
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I am all for lobbying and letting the people have their say. After all government is supposed to represent us.

To lobby their must be a clear mission with accurate facts and an achievable goal. I have not seen any of that so far in the emotive ramblings here.

As far as things being a done deal, I have just said that it is my opinion that we are not going to change anything but the time for response is when the RIA comes out following a PROPERLY guided campaign.

The way it should work is that someone should state clearly the objectives, what it is we are retaining and why we are retaining it. How it is going to be implemented if it is retained. Is it going to going in the LAPL which is a sub ICAO licencem, the ideal place for a sub ICAO rating or are you going to attempt to get all of the European states to agree to a variation for a sub ICOA rating on the EASA PPL? None of that has been clearly stated to this point in time.

Once you have formed your battle plan and have the MP's etc on your side with a clear logical campaign when the RIA comes out you will be able to respond clearly with what you want.

As far as the politics are concerned it has been demonstrated time and time again that the politicians get what the want. Take a look at the constitution, snuck in via the back door, galileo being paid for from farming money (when our farmers are suffering), the list goes on.........
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Old 14th December 2007 | 10:04
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From: Gt. Yarmouth, Norfolk
time and time again that the politicians get what the want
Collectively that is true. However, we have a duty to try and tell them what it is they actually do want

I don't think it is necessarily reasonable to expect those on the outside to present a full and detailed bueprint for an entire regulatory framework. We start however from a certain position, namely that we have rating which has existed for at least thirty years, that works, increases skills levels in pilots, that is affordable and which contributes to safety. From this position we have to educate the politicians to the idea that any changes which remove the IMCR and reduce to almost zero the money and training people have put in to getting and maintaining the rating are a bad thing; that this should not happen until a way is found either to allow the existing rating to continue in place along side any new licensing regime or to ensure that something equally effective is put in its place.

Such an approach accords with the concept of proportionality; it allows for the particular conditions of weather and airspace to be accorded proper place and allows for a rating to continue to be used in a country where it is well suited and designed to be used, without impinging in any way on the right of other European countries to reject the IMCR as a concent if they choose to do so (which they have).

I don't see anything wrong in this approach - anyone who ever campaigns for a change in the law in any area approaches it in a similar way; they do not produce a detailed legal framework, which is a matter to be determined by the government or parliament concerned. It is the basic principle which need to be established, not the fine detail.
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Old 14th December 2007 | 10:45
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It is the basic principle which need to be established, not the fine detail.

Agreed. At the moment that has not happened and is what I keep asking for. I outlined in my post above what the basic principles were and we still do not have a direction.

Yes lets keep the IMCR, what ar you going to attach it to, a cornflake packet or a licence? Which licence? To make this work a general direction has to be chosen.

My personal view would be that the avenue with the any likelihood off success would be to overturn the DAY/VFR aspect of the LAPL and have the rating added to that. Sub ICAO licence, sub ICAO rating. This was the view that EASA had in the first place.

Might upset the EAS guys a little but hey they are supposed to be representing all of GA.
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Old 14th December 2007 | 10:58
  #226 (permalink)  
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May I interject on this debate to suggest that the principle should be that EASA should accept the lowest standard of regulation which has a PROVEN safety record in ANY DEVELOPED part of the Western world.

This would probably mean that the IMCR AND the FAA IR could be accepted as European standards. We could also sort out all the anomalies on light aircraft weights and noise regulations.

They would probably also have to introduce new legislation to allow pigs to fly.
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Old 14th December 2007 | 11:05
  #227 (permalink)  
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Forget any idea of IMC flight using a LAPL. It will be a Day VFR (cf the NPPL) licence and will also include the 'restricted version' in order to allow the French to continue killing themselves with their 'Brevet de Basse'.

The IMCR needs to be promoted as a pan-ESA Rating, with the following objectives and privileges:

Objective:

To enable pilots to cope safely with non-VMC weather in EU airspace.

Privileges:

To fly IMC/IFR in airspace other than Class A without the inclusion of an Instrument Rating on the licence.

To navigate the aircraft by sole reference to instruments under circumstances which require mandatory compliance with defined routes.

To fly instrument approach procedures for which they have logbook endorsements to instrument approach minima +200 ft for precision approaches and +250 ft for non-precision approaches.

The IMCR should be available to PPL(A), CPL(A) and ATPL(A) holders.
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Old 14th December 2007 | 11:22
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Makes sense Beagle.

Maybe a look at the Canadian system of a 2 class IR for Inspiration. This would allow IMCR holders to upgrade to a Class 1 IR.
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Old 14th December 2007 | 12:28
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BEagle,

I'm not sure I understand why you say forget attaching it to the LAPL? To me this would seem to be the one where it would stand the best chance of success.

Personally, I don't see the reason not to argue for allowing it to be attached to either licence.

In any case, I think that that is just details, which is what I think Justiciar was saying. (Please correct me if I'm wrong Justiciar). Argue for the retension of the rating, and the the politicans and EASA work out how best to retain it, once they realise there will be a big revolt if they don't.

dp
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Old 14th December 2007 | 13:52
  #230 (permalink)  
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My personal view would be that the avenue with the any likelihood off success would be to overturn the DAY/VFR aspect of the LAPL and have the rating added to that. Sub ICAO licence, sub ICAO rating. This was the view that EASA had in the first place.

Might upset the EAS guys a little but hey they are supposed to be representing all of GA.
I couldn't agree more.

I don't think that what is today known as the UK IMC Rating (that is, IFR in Class D-G, with no ATS service and no implicit enroute clearance, and non-radio if OCAS for good measure) has ever had the slightest chance of being adopted Europe-wide.

There are political reasons (the NAAs i.e. old airline Captains and their unions would fight like hell) but also on the practical front some countries have a lot of Class C/A and not much Class E/G.

However, if the IFR option was not excluded totally, then one could work on a modular IFR scheme similar to Australia for example, which would then offer a grandfather route from the IMCR, so an IMCR holder would enter the scheme at the appropriate point.

I can see why the IFR option was scuppered - it was done to usurp any opposition from the old Captains to the LAPL, with its GP medical and the general deregulated "sporting" nature.

I suppose one could add an IFR option later on to the LAPL but this screws UK IMCR holders who will be left without IFR privileges until somebody gets around to pushing this through EASA. And the opposition from the gold plating commercial IFR lobby will not be any easier then.
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Old 14th December 2007 | 20:45
  #231 (permalink)  
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The IMCR should be available to PPL(A), CPL(A) and ATPL(A) holders.
Putting that forward will not get very far because as everyone knows, one needs an IR a long time before one meets the requirements to obtain an ATPL.

Nonsensical suggestions are only going to drag the whole idea down.

The proposals show a distinct lack of knowledge of future airspace proposals. Is Eurocontrol going to have to restart it's one sky and future airspace plans just so that thre UK IMC rating can be imposed on the rest of Europe?

As I said many posts ago, the UK CAA was going to have to revisit the IMC rating in the future with the revised classes of the lower airspace and the reduction in the use of Class A and expansion of classes D and E in the enroute environment.

Regards,

DFC
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Old 14th December 2007 | 20:56
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I can see why the IFR option was scuppered - it was done to usurp any opposition from the old Captains to the LAPL, with its GP medical and the general deregulated "sporting" nature.
IO,

That maybe what happened, but it shouldn't be such a difficult problem to overcome.

There's no reason not to have a basic GP medical for the basic LAPL, but require a more stringent (class 2 equivalent?) medical if someone wishes to exercise the privileges of an IFR rating which they added to the LAPL. In fact this is very similar to the current JAR PPL/IR. Someone wishing to exercise the privileges of their JAR IR is required to "upgrade" their class 2 medical to include an audiogram.

It should be an easy enough situation to sort without upsetting those that want a generally deregulated type of licence.

DFC, people sometimes let ratings lapse, because they no longer need their privileges

dp
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Old 14th December 2007 | 21:48
  #233 (permalink)  
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DFC, people sometimes let ratings lapse, because they no longer need their privileges
I don't get your point.

Regards,

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Old 14th December 2007 | 21:56
  #234 (permalink)  
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DFC, people sometimes let ratings lapse, because they no longer need their privileges
DFC I may have missed something but surely the point of allowing ATPL holders to hold an IMC rating is so that having flown for years with a multi-crew IR they don't have to go through the single pilot IR again (which would have lapsed soon after they started airline flying). Now I don't know the ins and outs of this but I know some ATPL holders do fly around in IMC single pilot on the IMC rating...not the IR, which is what I assumed BEagle had in mind when he made the suggestion.
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Old 14th December 2007 | 22:08
  #235 (permalink)  
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You may be confusing the UK pilots who obtained an ATPL having flown nothing more than a C150 for 1500 hours of which 100 was at night and JAR-FCL qualified ATPLs who are a totally different breed.

The only way to obtain an ATPL now is as follows;

Hold a CPL and a single pilot IR
Have completed an MCC course

Obtain a multi crew type rating and a multi crew IR

Amass a minimum total of 1500 hours with a minimum 100 hours night with 500 hours multi pilot and pass the required test.

If having at any stage one decides to do single pilot IFR flying privately, for the same price of doing the IMC renewal, one can do the single pilot IR test.

If the multi pilot IR is allowed to lapse then the pilot can not exercise the privileges of the ATPL or the multi pilot type rating included therein. They effectively become a CPL as far as privileges are concerned (assuming they have a valid Class 1 medical). If they only have a class 2 medical then they only have PPL privileges.

I don't know anyone who would spend the time and money to pass an IMC test when for the same time and money they could pass the single pilot IR test and not be restricted as per the IMC rating.

Regards,

DFC
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Old 14th December 2007 | 22:13
  #236 (permalink)  

 
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Perhaps they want a rating to be valid for 2 years...
Perhaps they don't want to fly in the airways, but want to get back to their farm strip in !!!!e weather.
Perhaps you should put the book down DFC.
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Old 14th December 2007 | 22:14
  #237 (permalink)  
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Forgot to say that of course one needs the ATPL exams also to get an ATPL!

Remember that one of the biggest arguments for the IMC rating is that those who may benefit from it can not get an IR. Those with an IR (even if it is only a multi-pilot one) don't have that problem and any proposal to attach the IMC rating to professional pilot licenses would come up against much in the way of claims about drumming down and reduction of safety in public transport.

Of course remember that one can if one chooses hold a PPL and a CPL and an ATPL at the same time. Few pilot can be bothered to pay the 5 yearly fee 3 times over though.

Many do however, hold both PPL and CPL or both PPL and ATPL. The fact that they hold an ATPL does not affect in any way the rights and responsibilities and limitations of operating using the PPL. i.e. the ATPL is simply dead weight in the pocket while flying a microlight.

Regards,

DFC
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Old 14th December 2007 | 22:16
  #238 (permalink)  
 
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DFC

What about the "old" CAA ATPL holders now in their fifties, 10,000 or more hours to their credit, did the exams etc etc, but now find themselves about to be stripped of their ATPLs.

What about the "old" CAA BCPLs, the true career instructors who have no other careers to turn to, never had any intention or desire to move on to a commercial career and are the true main stay of many a fly club / school who are about to be stripped of their ability to earn a living. These are also the guys with 10, 20,000 hours, seen it all, done it all so far as teaching is concerned.

How does that work?
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Old 14th December 2007 | 22:24
  #239 (permalink)  

 
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I forgot to say...

The IMC is given away free for anyone:

Who has passed an IR check flight in the past 2 years

So another reason for a MC IR holder to use one....it is FREE...no test required.
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Old 14th December 2007 | 22:25
  #240 (permalink)  
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Perhaps they don't want to fly in the airways, but want to get back to their farm strip in !!!!e weather.
Hopefully, they would not risk their career flying in such cases.

Remember that current JAR-ATPLs are going to be earning a reasonable wage. I don't think that doing a quick IR renewal test each year is going to break the bank.

I spend less doing single pilot IR renewals each year than many IMC holders I know spend renewing their IMC rating. Mostly because I simply expeditiously complete the test and get the signature rather than the old....ah you need a brush-up flight....and another one....before doing a test that takes longer than the IR renewal.

For that I also get the multi-engine piston signed off which of course is extra for the IMC rating holder.

The only thing we both get is the exemption from having to do the 1 hour with an instructor for the SEP renewal.

Keeping the sep going means that one can fly microlights without having to pay for a microlight rating or having to complete any minimum hours in the past 13 months etc etc not to mention that as a JAR-FCL instructor, one can teach SEP, MEP, IR, IMC Night and Microlight.

You really do get a lot for your money!

Regards,

DFC
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