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EASA? What a joke!

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Old 10th Dec 2007, 22:08
  #101 (permalink)  
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DFC forgive me if this is a stupid question...or if I've missed the answer to this but what is your personal view on the IMC rating?
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Old 10th Dec 2007, 22:58
  #102 (permalink)  
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My pesonal view is that the idea is sound but the practical application is flawed in many ways.

There are so many flaws but as an example I would much rather see pilots having the training to as many put it get themselves out of trouble but still have the legal obligation to report the fact they they got into trouble in the first place.

Does one really have to fly in IMC to practice instrument flying or instrument approaches - NO.....Thus having completed the required training there is absolutely no further requirement to fly in cloud again in order to maintain the basic skill set that is then used to save a foolish unplanned excursion into IMC.

Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?

As i said.........flawed application of a good idea.

Regards,

DFC
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Old 11th Dec 2007, 06:29
  #103 (permalink)  
 
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Does one really have to fly in IMC to practice instrument flying or instrument approaches - NO.....Thus having completed the required training there is absolutely no further requirement to fly in cloud again in order to maintain the basic skill set that is then used to save a foolish unplanned excursion into IMC.

Same for the IR

Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

You are confusing the requirements for public transport of paying passengers (under an AOC), with private flight in which the State has no business to interfere other than to minimise 3rd party risk, and 3rd party risk in GA is utterly negligible. GA passengers, assuming a nonzero IQ, are assumed to be aware they are not getting the same level of safety as on a 747.

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

As above.

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?

As above.

Get real, DFC. You speak like a long retired ex CAA IR examiner. Most of the old guard of the great IR gate in heaven see the IMCR as a back door IR and slag it off accordingly. Any instrument privilege is only as good as pilot currency on type, etc.
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Old 11th Dec 2007, 07:46
  #104 (permalink)  
 
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DFC

I agree.

Again I dont believe you have flagged up defects with the IMCr - rather addressed endemic licensing issues that are equally as relevant to the IR holder and the PPL.

Moreover it is important to distinguish good practice from the law.

For example flying over ground fog in a SEP with an IR is perfectly legal, but the same flight with paying passengers is not, even with a PT6 up front. Is the former unsafe, is it bad practice or is it acceptable risk taking. Of course if the departure and arrival airports were clear of fog the IMCr holder could make this flight - but is he more or less likely to do so than the IR holder? If you believe Bosey with his clubhouse full of IMCr holders on a marginal weather day it is the IR holder who is far more willing to fly in "poor" weather. When the engine quits I dont suppose the IR holder will do any better than the IMC holder.
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Old 11th Dec 2007, 08:34
  #105 (permalink)  
 
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I have a simple solution to your when an engine quits suggestion, make any Instrument flight a multi engine only exercise.........

What is the purpose of the IMCR then Fuji if not for flying on a marginal weather day, bragging rights in the bar that you are an 'instrument pilot' but never actually going anywhere near marginal conditions in case the engine quits?

You also did not answer my question about why you don't think other posters comments stack up.

You can't just dismiss things that you don't agree with without an explanation.

None of your points in the last dozen or so posts actually give a reason to save the IMCR they are just you constantly battering us with your opinion.
You are on a blind mission to shoot anyone down who does not agree with you.

I think DFC's posts about the type of aircraft being used and the skills are relevant ones. Not least because those are exactly the type of arguments being used to get rid of the rating. So rather than just repeating yourself by saying not relevant, not relevant please come up with a logical counter argument to fixing the situation that will convince those that are so anti. It's no good just keep putting others down when they come up with reasonable arguments its about countering them.

We would like you to lay out clearly your case for saving the IMCR without plagiarism from other sources and a clear plan to what you think we should do to save it.

I realise it will be a struggle for you without resorting to being rude but go on try it, you my even get taken seriously.
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Old 11th Dec 2007, 08:42
  #106 (permalink)  
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Moving on from the flaws of the IMC rating does anyone have any idea what sort of basis a legal challenge to EASA would be formed on?
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Old 11th Dec 2007, 08:47
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Moving on from the flaws of the IMC rating does anyone have any idea what sort of basis a legal challenge to EASA would be formed on?
You are kidding? Try asking a solicitor familiar with European law and aviation law in particular.

There are a couple of possible areas that have been identified but they are not high win chances and would be very expensive to pursue.

You get what you pay for when it comes to legal advice.......
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Old 11th Dec 2007, 10:20
  #108 (permalink)  
 
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Is the present issue about EASA's powers, which are defined by legislation from the European Parliament, or have we moved beyond this? If we have, then it a case of ensuring that their powers are exercised in accordance with the legislaqtion; otherwise it would be about influencing the form of the legisdlation and any power to allow national differences, which i suspect there would not be. However it begs the question why the French may be allowed to restrict access to altiports by way of a requirement for differences training whilst the UK may not be allowed, for example, to permit the flying of an ILS in IMC without an IR or permit let downs through cloud from VFR on top. Being devil's advocate, the difference in this example is that let downs through cloud are flights under IFR (as defined by ICAO) and EASA is unlikely to wish to file a difference with ICAO allowing this to be done.

What still concerns me is that the new "sports licence" being proposed is itself going to be a sub ICAO licence, thereby severely restricting the ability of pilots to convert or validate their licences in non EASA countries. This seems to be as important an issue as the six pages of mud slinging we have hade here over the IMCR
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Old 11th Dec 2007, 10:40
  #109 (permalink)  
 
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Justicair, you have to look at it the other way round. There will still be a fully ICAO compliant PPL in the form of the EASA PPL just as with the JAA PPL. You will be able to add any ICAO compliant ratings to it that you want, ME, IR, SET etc etc etc.

The LAPL is going to be a European wide NPPL. So those that have an NPPL actually gain. It is also aimed at the permit type flyer who is really only interested in the local bimble or day vfr only travel. So for the permit tourer a licence that is cheap and easy to maintain like the NPPL but allows them to go into Europe is a benefit and keeps in with the low cost theme of their aviation.

I would be interested to see how many of those types who would go onto the LAPL would actually go an fly outside of Europe.

For the more adventurous the route of an ICAO PPL is still there and so they can go off an fly around the world and add lots more exotic ratings. The bridge between the two still has to be finalised but just as with an NPPL now you can convert to a JAA PPL you will be able to convert an LAPL to an EASA PPL.

For those that already hold a JAA PPL it is just a paperwork exercise.

The IMCR would have been a natural addition to the LAPL but it was shot out of the water when certain parties insisted the LAPL was to be a day VFR only licence. So the actual licensing structure makes sense largely, it is just things like the IMCR that have become orphaned as a result.
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Old 11th Dec 2007, 10:40
  #110 (permalink)  
 
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Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?
Care to expand on these, particularly the last?

Surely the first two of these issues are related to Aircraft Operations, not Personnel Licensing. And they are addressed in the ANO, but with much less specific regulation than JAR-OPS 1, a difference that seems reasonable for the needs of private flying.
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Old 11th Dec 2007, 11:47
  #111 (permalink)  
 
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Stellair,how does what you have just posted on the IMC verses IR thread square with your comments on this thread?
QUOTE:
"mark,
Get that IMC . It's a great introduction to Instruments, unique to the UK, cheaper and is a priceless rating should you ever need to use it in anger for clearing bad weather or getting into an airfield in less than perfect VMC during your hour building to C.P.L.
When I did mine I had a very experienced instructor and he made me fly to IR limits which gave me a great leg up for things to come."
UNQUOTE:
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Old 11th Dec 2007, 11:50
  #112 (permalink)  
 
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Are there we go again, nobody can resist the personal attacks can they.......
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Old 11th Dec 2007, 12:21
  #113 (permalink)  
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The rules are clear........you can not depart on a VFR flight unless the weather (reported and forecast) indicate that the flight can be made safely VFR.

IFR flights are required to carry suficent fuel for destination and alternate (or 2 alternates if limited met reporting etc etc for first alternate) and having reached the furthest alternate be able to hold for 45 minutes in the case of propeller aircraft.

IO540 - the comander is legally required to check pre-flight that they have the required fuel, oil and coolant.

Unfortunately, many IMC rating holders fly IFR without ever having considdered the fuel requirements, the alternates and so on and thus they have not acted legally if pre-flight they planned to fly IFR for any part of the flight. Of course if they are forced to abandon IFR enroute due to unforecasted IMC then they do not have the oportunity to plan in advance but they should report the circumstances so that the incident can be investigated.

Many IMCr holders will depart VFR knowing that they are going to have to fly IFR at some stage enroute. Thus there is a requirement to plann for an alternate should the weather not be as planned (VFR at destination).

We have had the debates here on PPRuNE. Many IMC rating holders fly as if they had an IR and use minima not appropriate to their rating.

Specifically, bookworm, there is no requirement for an IMC rating holder to apply higher minima at the alternate aerodrome when planning the flight (if they have even bothered to plan one) than at the destination i.e. the IMC rating holder can plan to a destination with an NDB approach and have an alternate with an ILS and use the 500ft DH and 1800m as minima where an IR holder will be obliged to apply non-precision minima at the alternate which could be higher than the IMC rating 500ft limit for a precision approach.

Overall if you were a citizen of another European country would you be happy with your government through the NAA permitting the IMC rating in that country with all the confusion that still surounds it so many years after it was started?

Don't forget that any NAA agreeing to an IMC rating will have their government minister thinking more about what the voters think that PPLs not being able to fly VFR into IFR IMC without submitting a safety report.

This is very much a political issue and one must wonder if so many foreign pilots wished their NAA had a similar rating, they never asked for on in their home country........and as far as I am aware, no UK IMC rating holder has ever applied to a foreign NAA for permission to exercise the ratying in their airspace.

Finally, one confusing issue in the UK is the fact that when you get your PPL, you are not permitted to fly to the limits of VFR.........you have to get an IMC rating to be able to do that. Getting rid of the IMC and getting rid of that very confusing licensing restriction unique to the UK will go hand in hand.

The altiport issue is a non-starter..........many airports have requirements that pilots must meet before flying in to them. For example, to fly into London City requires approval, simulator tests and so-on. They are justified on safety grounds in the UK just as elsewhere.

Regards,

DFC
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Old 11th Dec 2007, 13:14
  #114 (permalink)  
 
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The LAPL is going to be a European wide NPPL. So those that have an NPPL actually gain. It is also aimed at the permit type flyer who is really only interested in the local bimble or day vfr only travel. So for the permit tourer a licence that is cheap and easy to maintain like the NPPL but allows them to go into Europe is a benefit and keeps in with the low cost theme of their aviation.
That begs a few questions:
  • Will the EASA version of an ICAO PPL be any more difficult than it is at present? We would not want to see it made more difficult on the basis that it is only gained by people as a stage on the commercial route
  • If the LAPL is Europe wide, will we also see a pan Europen Permit system removing the need there currently is for Permit aircraft to get permission from some countries and not others?
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Old 11th Dec 2007, 13:45
  #115 (permalink)  
 
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Fighting on the wrong front?

I have that agree that the we need the IMCR or an EASA equivalent but all this thread seems to be focusing on is pilot licence issues, EASA is bigger than that!

Part M maintenance will be comming to an aircraft near you very shortly, the rules are changing by the day and reams of paperwork are having to be re-writen by engineering company's resulting in licenced engineers stuck in the office and not working in the hangar.

Who is going to pay for all of this pen-pushing?....................... the customer of course. There is little doubt that this part M will be pushing up the cost of maintenance and with supervising engineers having to spend so much time with the paperwork inspection standards will start fall due to time pressure.
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Old 11th Dec 2007, 13:45
  #116 (permalink)  
 
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As I understand it there will be no changes to the existing PPL when it transfers to EASA. I don't actually think the EASA PPL is viewed as the commercial route, I think in the future it will see the prospective commercial guys going direct into the MPL without ever touching a light aircraft. One good thing to come out of is the end of the hours builders, which will hopefully drive the career instructor market and make it attractive enough for people to want to do it as a career.

I don't know about the Pan European permit thing, one of our PFA types might know more on that.
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Old 11th Dec 2007, 14:24
  #117 (permalink)  
 
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Bosey

Let me set out the position for you.

This is an internet forum. It is full of people a) with nothing better to do with their time, b) who think they know it all, c) want to keep up to date and learn from others, d) enjoy a bit of banter.

You and I have had a bit of banter over the IMCr. To the extent it is taken seriously there are some issues on which you and I clearly disagree. There is however a danger that the tone of the debate detracts from the forum. I don’t want to go down that road any further. It is you who dont want to be my friend and think I am totally mad which is fine by me.

However, the subject matter I believe is really important for two reasons:

a) I don’t think enough exposure has been given to the impact of the loss of the IMCr and for that matter other changes that will come from EASA,

b) and judging by all the emails I have received already and from the number of people that have already signed the petition I think there is widespread support for retaining the IMCr.

Stirring the pot in the way we have has produced a deal of interest. The threads, unlike in the past, have not been quick to die. There have been some excellent contributions. I think this is a significant step forward.

Now I know you want to goad me by the use of some well chosen terms - “plagiarism” comes to mind as but one example. However let me explain this:

I do not have the answers to all or even some of the questions - I am not an expert. I am not on any of the representative bodies. I certainly do not have the head start doubtless you and some others have.

What I do have is a belief that the abolition of the IMCr is a retrograde step. I also believe is that the vast majority of pilots share my view. I intend to ensure as many as possible are aware of what is taking place.

I believe that changes in legislation are not readily introduced if the regulators meet with significant resistance. I also believe that the IMCr is fundamentally a safe rating for a pilot to add to their license. I intend to gather as much evidence as I can to ensure that conclusion is sound. Inevitably, and as anyone would expect, that will rely on the work of others.

So, to conclude, I am glad we have raised the profile of the issue at least on PPRuNe anyway.

I know you don’t agree with me, or with my approach. I understand you think the battle is already lost. I know you think AOPA have done / are doing all they should. It so happens I think you are wrong. Fall out with me over that, tell me I am mad, or whatever, it doesn’t matter. Persuade me that all the people that have signed the petition are wrong or that the IMCr is fundamentally unsafe based on the evidence over the last forty years and I will sit up and take note.

DFC

Where is the evidence that all these pilots are doing what you suggest? I have started to go through every reported accident and incident and I have yet to find one involving an IMCr pilot in the circumstances or anything like the circumstances you outline.

There are many things a pilot is not specifically prevented form doing by law. In that respect the legislation can never be totally prescriptive. It recognises that a degree of responsibility comes with the license. More importantly there are clear recommendations regarding the limitations of the IMCr imparted both by the instructors and the CAA.

In answer to Bosey’s question about SEP flights personally I don’t think a pilot should depart with the cloud on the deck in a single piston whereas I do in a turbine. Clearly there are many IR pilots who would disagree but at least there aren’t any IMCr pilots who could disagree. Bosey exercises his judgement which he is entitled to do - some would argue he should not have that entitlement in these circumstances.

In exactly the same way there has been a lively discussion about whether a VFR pilot should depart if the forecast suggests he cannot maintain a given seperation from the ground. Yet another example is whether an IRated pilot should fly if there is a risk of icing (and the aircraft does not have certified de-icing). The law recognises for the private pilot these are calls of judgment. My own opinion is that it is best left that way.

If you are so bothered about all these IMCr pilots setting out in aircraft that are not certified for flight in IMC / IFR and departing with the destination at minima and no alternate apply the same standards to both IR and IMCr pilots in this regard so far as the legislation currently stands and enforce those standards for both. I suspect you might well end up prosecuting more IR holders than IMCr holders.
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Old 11th Dec 2007, 14:27
  #118 (permalink)  
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You are kidding? Try asking a solicitor familiar with European law and aviation law in particular.
It was more an attempt to steer things away from the arguements about the IMC rating....I don't know any aviation lawyers...but my dad was a European court judge for seven years.
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Old 11th Dec 2007, 14:56
  #119 (permalink)  
 
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I know you don’t agree with me, or with my approach. I understand you think the battle is already lost. I know you think AOPA have done / are doing all they should. It so happens I think you are wrong. Fall out with me over that, tell me I am mad, or whatever, it doesn’t matter.
See there you go again, you are like a dog with a bone. I ask you quite reasonably to actually state your case and you go off attacking AOPA and me again.

You see every exchange as some opportunity to pour out your anti AOPA bile.

So lets go back to my original question, lets see if you can actually state your case in a calculated manner without resorting to attacks about what you see OTHERS having failed to do. YOU are trying to gain support, I am interested in hearing your case. So far you have failed to state one.

As for your petition, 200 (including Laura Croft and Basil Brush) out of 18,000 is failing to get me excited in the same way as it is you.
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Old 11th Dec 2007, 14:59
  #120 (permalink)  
 
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As for your petition, 200 (including Laura Croft and Basil Brush) out of 18,000 is failing to get me excited in the same way as it is you.
It is though a pretty good step in the right direction.
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