EASA? What a joke!

[sunday driver]

Fuji

The more recent posts, focussing on facts and statistics, raise the credibility of the debate, and of the participants.

Let's keep it up - it's the only way to inform and influence others who may be watching.

SD

PS The IMCr dramatically raised my respect for the demands of flying IMC and has enabled me to extract myself from IMC without drama. IMHO it should be a part of every PPL's kit, along with instruction in basic aerobatics.

[Fuji Abound]

Thank you - I hope that approach can be maintained.

[bookworm]

No, I use ICAO annex 6 part 2 - the standard that the UK CAA says UK aircraft operate to with the exceptions noted.

Annex 6 part 2 is for international air navigation. It would be perfectly reasonable to expect UK aircraft engaged in international air navigation to comply with it, and carry a 45 minute final reserve. Within the UK, the fuel planning requirements are simply as I have previously quoted from the ANO. I'd be very happy to see IMC rated pilots taught that a 45-minute final reserve is good, standard practice. But it would be a bit daft to emphasise to applicants for a national rating adherence to international regulations, wouldn't it? There is no difference between fuel planning requirements for an IMC rated pilor and an instrument rated pilot.

There is no exception for fuel planning requirements

That is a matter between ICAO, the CAA and the UK legislature. As you well know, many amendments were made to the ANO for conformity with ICAO Annex 6 part 2. Why this was not one of them I don't know.

or to the fact that a VFR flight can not depart for anything other than a local flight unless the weather is VMC all the way to destination.

As usual you're twisting regulation by placing your interpretation on it. The ANO says:


Art 52 ... (a) that the flight can safely be made, taking into account the latest information
available as to the route and aerodrome to be used, the weather reports and
forecasts available and any alternative course of action which can be adopted in
case the flight cannot be completed as planned;

That's all. No requirement for VMC to destination to depart VFR.

[DFC]

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).

Please do not use stats that work against your argument for having the IMC rating!

You are saying that despite having the IMC rating available, a large proportion of accidents involved loss of control in IMC. Unless you expect EASA to require every pilot to hold an IMC rating, you are only proving that having it as an optional addition to the PPL does not improve safety.

Please also remember that many CFIT accidents are in VMC and were never near any IMC.

----------
Bookworm,

I think that you are misguided if you think that you are safe flying IFR without as a minimum complying with Annex 6.

Your argument about only applying to international navigation does not wash because if I am holding at a UK aerodrome I am on an international flight and the UK Government assures me through Annex 6 and the differences filed that I will not have my hold time extended by a sequence of local pilots having to jump ahead of me in the sequence because they do not bother to carry reserves or diversion fuel.

I am aware that some local pilot may jump ahead because they hold this IMC rating thing that permits them to file IFR but not be in a position to enter class A (where the hold is) or even to fly a hold. Annex 1 explains that to those who read it properly.

Regards,

DFC

[dublinpilot]

I think that you are misguided if you think that you are safe flying IFR without as a minimum complying with Annex 6.

Bookwork made no claim was to what was safe. He simply said that you were incorrect to claim that IMC holders and IR holders had different legal requirements regarding fuel. He's made that point pretty clear. IMC holder and IR holder have the same requirements, for domestic flight. IMC holders can't make international flights.

Your argument about only applying to international navigation does not wash because if I am holding at a UK aerodrome I am on an international flight and the UK Government assures me through Annex 6 and the differences filed that I will not have my hold time extended by a sequence of local pilots having to jump ahead of me in the sequence because they do not bother to carry reserves or diversion fuel.

On the contrary. It's your argument that does not wash, becuase that person in the hold could just as easily be an IR holder. The IR holder on a domestic flight, is operating to the same rules as the IMC holder on a domestic flight.

dp

[Fuji Abound]

You are saying that despite having the IMC rating available, a large proportion of accidents involved loss of control in IMC. Unless you expect EASA to require every pilot to hold an IMC rating, you are only proving that having it as an optional addition to the PPL does not improve safety

The fact that the majority of pilots involved had neither an IMCr or IR is significiant. It would sugest if you hold either you are much less likely to be involved in either. It is also interesting that of those pilots with an IR or IMCr more had an IR than IMCr out of a much smaller population or IR holders.

Please also remember that many CFIT accidents are in VMC and were never near any IMC.

Not so.

There were very few CFIT in good VMC. Marginal VMC or cases were the visibility could not be established accounted for the vast majoirty.

Bookwork made no claim was to what was safe.

You are correct.

I think you need to distinguish between what the law permitts, and what may or may not be safe. If you are going to suggest that the procedures followed by IMCr pilots which go beyond what the law requires are unsafe then you are also going to need to provide evidence to support that contention rather than anecdotal account simply because you feel it must be so from a possible perception that private pilots generally are a bunch of cowboys unitl they have a professional rating (which some perceive is the case of an IR)

There are many reasons why pilots not qualified to do so unintentionally enter cloud. Some very interesting studies have been undertaken at Cranfield and elsewhere. However not surprisingly the the process also starts from a perception that TAFs are more accurate than they are.

[rustle]

Originally Posted by Fuji Abound

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.

Demonstrably not true.

FLYER forum
PPL/IR forum
AOPA forum

Don't know about PFA or UKGA but wouldn't be surprised to see it there too.

Stick to facts, or at least if you're going to lie about stuff don't be quite so obvious - credibility is everything in these discussions, and is currently nothing.

[Fuji Abound]

Rustle

Lie = the intent of being untruthful

I had no idea that there are links to the petition on these forums.

Perhaps you would identify them as that would be most helpful.

Thank you to those who have posted these links presumably following the original post on PPRuNe - at least PPRuNe can still hopefully say "you read it here first"

Hopefully there is so much interest in this the word will spread very quickly.

criditability .. .. .. is currently nothing

Naturally, I am sorry that you believe that to be so.

EDITED to add:

Just had a quick look on AOPA. Do you mean this one:

http://www.joinaopa.com/forum/viewtopic.php?t=263

which seems to have had the link added on the same day I made the comment, so I suppose unless people were very qucik to sign up, at leat so far as the AOPA bulletin board is concerned by comment stands.

[Fuji Abound]

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!

[S-Works]

You better have a word with your 'campaign manager' Julian Story then as he cross posted it all over the world. And it seems reading the response on a number of his cross postings that I am not the only one with reservations.
If you can't even get your supporters in line how are you going to deal with the regulators.......

A lie or an omission?

You still have not answered the question of how you plan to pitch this. It is all well and good screaming to save the rating which I am all for but how exactly are you going to save it?
Which licence do you intend on attaching it to and how do you plan on achieving that?

And I think if you are going to quote Irv Lee you could include all his comments and acknowledge him.

[David Roberts]

I have just posted the following on another thread re Norway and EASA:
I am just leaving for a meeting of the MDM.032 core group in Cologne, and there will be further discussion on the content of the LAPL (which was formulated in a sub group with separate people).
There is still two further chances to influence the process - (1) responding to the CRD - Comment Response Document - and (2) when the NPA is published, probably March 08
I suggest everyone looks at the CRD explanatory note which is in the third box down at:
http://www.easa.europa.eu/home/r_crd.html
You will see from this that the question of an IMCR / IFR rating was not the primary concern of respondents, but then the responses came from all over Europe including many at the very light end of GA (microlights).
The other related documents are there too.
It took an age for all the 8054 comments in late 2006 to be assimilated by EASA - a major task - hence the delay in publication.

[DFC]

Dublin Pilot, etc,

Unfortunately, it is a misconception (that even I held for a while) that what is legal and what is safe are two different things.

If you believe that it is unsafe to fly IFR without a proper alternate and proper quantities of fuel for diversion hold etc then even if the law in one part says to fly you only need enough fuel to take-off and land you can not use that as an excuse for unsafe operation which is the other part of the law that you will be breaking and your insurers will use to avoid their bill.

Remember that the CAA will prossicute everyone who runs out of fuel. They will not prossicute under the ANO article regarding pre-flight planning and amount of fuel to be carried they will use Reckless endangerment or similar.

Thus if the vast majority of the world use destination , alternate and holding fuel as a minimum and it is the international standard you would find it hard to convice a court they they are wrong and you are right in terms of safety and thus hard to disprove an unsafe operation.

--------

The difference is not between IR and IMC holders.........it is in the way that the rating is for the most part used. Far too many IMC holders will depart on VFR flights with VFR planning and VFR fuel knowing that they will at some stage convert (even for a short while) to an IFR flight. The training, the CAA guidance and as per your post, peer pressure does not enforce the knowledge that such flying is illegal and can result in an accident or at a minimum unnesessarily disrupt normal properly planned and conducted IFR flights.

I am simply trying to get the message across that the vast majority of the flying world look at the IMC rating in part as legalised corner cutting i.e. cut the corner on training,cut the corner on testing, cut the corner on revalidation and cut the corner on operational requirements and you have cut so many corners of the cheese that all that is left is several holes.

--------

Marginal VMC or cases were the visibility could not be established accounted for the vast majoirty.

Thanks for confirming that there is no evidence of IMC flying in the majority of cases.

Regards,

DFC

[Fuji Abound]

Bosey

There you go.

It certainly would be a disgrace. If you have a room of European 'peers' judging your proposal (to keep an IMC rating), you have to remember some basics :

1- Some of them have entirely different ways of using 'airspace' and unless detailed work was done with explanations they could well be anti IMC rating as they would try and visualise it in their country, and not see the same picture. ie: we can be talking 'apples', they can be sitting their visualising 'pears'.

For example, take Spain vs UK just for one of many. UK has enormous volumes of Class G, Spain doesn't, it uses Class E where we would expect G. We use our IMC ratings mainly in our enormous Class G volume, with 'mixing with commercials' happening (if at all) under strictly controlled conditions under radar for arrival. If you then consider Spain, with Class E as the 'main' airspace and commercials routing through it all the time, their commercials are not going to be too happy about a brand NEW concept to them (explained in a few minutes) of PPLs mixing it with them in IMC conditions after 15 hours training - of course they are not going to be keen because they are visualising what is happening differently!

2- Some of the people 'in the room' have totally different attitudes to 'safety' - for example France have between 60 and 80 fatalities a year in aviation and seem perfectly happy with that. Their attitude seems to be 'it's a dangerous sport, like mountain climbing, etc, so if they fly, don't be surprised if some of them die'. When you look at hours flown or aircraft numbers and deaths, fatalities in Italy are even more common, and 'who cares'? And these people actually have votes over whether we keep our IMC rating which we consider a huge safety benefit!

I'd love to see the 'pitch to keep the IMC' to see what arguments were put across in what way with what emphasis - and how long it lasted, given some of the attitudes listening.

If we'd come out of the meeting with a positive thumbs up, then basically we would be on a train, only having to make sure we didn't fall off it. As it is, we seem to have missed the train, which means enormous effort to chase it and try and board it, and that may or may not be possible, but it's certainly harder work!

The actual concept of presenting such a rating to other countries in a brief 'pitch' and asking them to understand it fully is flawed.

Irv Lee

You better have a word with your 'campaign manager' Julian Story then as he cross posted it all over the world. And it seems reading the response on a number of his cross postings that I am not the only one with reservations.

If you can't even get your supporters in line how are you going to deal with the regulators.......

My main objective was always to put this issue in front of as many pilots as possible. I am really glad to see the amount of debate that is taking place.

DFC

The difference is not between IR and IMC holders.........it is in the way that the rating is for the most part used. Far too many IMC holders will depart on VFR flights with VFR planning and VFR fuel knowing that they will at some stage convert (even for a short while) to an IFR flight. The training, the CAA guidance and as per your post, peer pressure does not enforce the knowledge that such flying is illegal and can result in an accident or at a minimum unnesessarily disrupt normal properly planned and conducted IFR flights.

Please would you let us know on what evidence you are relying for that assetion - or is it just anecdotal?

Euro MP


I am pleased to say that I have now heard directly from one of our Euro MPs. He has confirmed to me that the reports of the impact his submission had were very positive and a meeting will now ensue at which he intends to set out the views of so many UK private pilots. I was really pleased to receive this news because it would seem this issue is now at the fore front of the debate.

[Fuji Abound]

Bosey

Oh, I meant to ask, would you like to give us an update as to how AOPA are progressing with this issue at the moment please? Obvioulsy anxious that we all work together if we can.

[dublinpilot]

If you believe that it is unsafe to fly IFR without a proper alternate and proper quantities of fuel for diversion hold etc then even if the law in one part says to fly you only need enough fuel to take-off and land you can not use that as an excuse for unsafe operation which is the other part of the law that you will be breaking and your insurers will use to avoid their bill.

DFC,

I think you are in your own little world, trying to argue with things that weren't said. What I said was "Bookwork made no claim was to what was safe." That's all I said about that. Nowhere did I or Bookwork say that it was either safe or unsafe to plan in such events.

The difference is not between IR and IMC holders

That is all the Bookwork was trying to get across to you.

[dublinpilot]

Bose & Fuji.

Will the two of you please call a truce, or take your bickering to pm? It helps noone, and brings both of your campaings into disrepute.

The important stuff is stuff is getting lost in pages of "AOPA didn't do x", followed by "You ought to get your facts right".

dp

[S-Works]

No bickering on my prt DP, I merely asked questions which Fuji has yet to answer. He takes every post as an opportunity to attack me or AOPA or both.

So I will ask again, now you have this campaign in front of a full 250 of the 18,000 pilots in the UK, what are your proposals for the future of the IMCR?

It is obvious that it can't stay as it is because there will be no licence to attach it to. So what is your proposal? I am sure your Euro MP will ask the same question in due course.

[Fuji Abound]

Dublinpilot

Yeah - I would love too.

Genuinely with out wishing to pursue it in swift order there was a pathetic post about getting my facts right because I commented that the link to the petition was here, then clever remarks abouts lies or omissions and complaints about not quoting the whole of a post (most of us quote the bit we think relevant).

Quite honestly I think it is pathetic but there seems very little I can do about it. I am happy to ignore it except it worries me that some take these remarks seriously and that there is a concerted effort to side track a worth while campaign. I dont want that to happen.

What do you suggest?

"If you have one enemy you have one problem, if you have no enemies you dont have any problems" - well I think I have two enemies and there is not much I can do about it.

Edited to add:

Well Bosey has crossed with me on the usual theme.

For the last time - yes there are only 250 names on the petition, I know. Yes, we might be wasting our time. Yes, you have made a whole load of very valid comments - and no, I dont have all the answers.

In the interests of harmony I am not going to reply to another of your posts.

There are others I am sure who are better able than me.

I am just going to leave it at that and let you have a free hand in addressing whatever I say as you wish.

and no it is not personal - I just dont agree with the spirit or substance of some of your comments.

[dublinpilot]

Bose, it may not seem like bickering to you. But to the rest of us, it's obvious that both yourself and Fuji are carefully disguising your bickering as seemingly reasonable comments. But we can all see that each of you is just offering a red flag to the other bull. You are each as guilty as the other.

Call a truce or take it to pm.

dp

[dublinpilot]

What do you suggest?

Me? I suggest that you stop attacking AOPA (and for the sake of pease refrain from any mention of AOPA for awhile..good or bad), and Bose stops provoking you and asking you pointed questions, and simply waits and sees where your campaign goes.

No appologies, no climb downs, no need to agree with this post or comment on it......just ignore one another on this particular issue for a few days until everyone calms down. We'll all be better off, and we all might get a little closer to our common aim...retention of IMC rights for the masses in some shape or form.

dp