IMC rating - press briefing
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Well done Chaps.
You have represented the true interests of all UK GA flyers today. Very refreshing
How can you all now ensure that you people stay involved and represent our interest rather than allowing the ''Associations''!!!! to take over, as they will surely try to do.
Rdgs Orions***
You have represented the true interests of all UK GA flyers today. Very refreshing
How can you all now ensure that you people stay involved and represent our interest rather than allowing the ''Associations''!!!! to take over, as they will surely try to do.
Rdgs Orions***
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You might also think about contacting and trying to get GATCO on side, if you haven't already. They might be able to make representations on your behalf, many of their members will have had (hopefully positive) experiences of controlling IMC rated pilots.
ABOUT THE GUILD
Formed in 1954, The Guild Of Air Traffic Control Officers (GATCO) is an independent professional organisation which exists to promote honourable practice and the highest standards in all aspects of aviation.
It is dedicated to the safety of all who seek their livelihood or pleasure in the air. These ideals have been sustained over the years and GATCO continues to provide a substantial voice for the profession of air traffic control (ATC).
Our membership comprises Civil and Military Controllers and Associate Members including Flight Information Service Officers (FISO) and military Fighter Controllers.
In addition, we have a growing number of Corporate Members who support the aims of GATCO and in turn can benefit from the access to worldwide air traffic control specialists.
Our membership exceeds 2000, providing a wealth of professional and technical expertise which enables GATCO to actively participate in the development of both UK and International ATC.
As such GATCO is recognised and respected worldwide as an influential and professional aviation body.
Formed in 1954, The Guild Of Air Traffic Control Officers (GATCO) is an independent professional organisation which exists to promote honourable practice and the highest standards in all aspects of aviation.
It is dedicated to the safety of all who seek their livelihood or pleasure in the air. These ideals have been sustained over the years and GATCO continues to provide a substantial voice for the profession of air traffic control (ATC).
Our membership comprises Civil and Military Controllers and Associate Members including Flight Information Service Officers (FISO) and military Fighter Controllers.
In addition, we have a growing number of Corporate Members who support the aims of GATCO and in turn can benefit from the access to worldwide air traffic control specialists.
Our membership exceeds 2000, providing a wealth of professional and technical expertise which enables GATCO to actively participate in the development of both UK and International ATC.
As such GATCO is recognised and respected worldwide as an influential and professional aviation body.
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A great many people have mentioned the opposition from the commercial pilot sector. ( I suspect that this ,means the ATP group, as the FIs are busy teaching IMC).
If this is the case, perhaps we could mobilise the group of ATPs who currently teach and examine for the IMC, to outline the benefits as they see it. Fight the enemy from within / divide and conquer etc.
If this is the case, perhaps we could mobilise the group of ATPs who currently teach and examine for the IMC, to outline the benefits as they see it. Fight the enemy from within / divide and conquer etc.
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It is not the ATP holders it is the European Cockpit Association. The UK guys it seems on the whole are behind the IMCR, it is their union BALPA that needs to put pressure on all of the other unions that form the ECA to agree.
BALPA running a campaign would be a good start.
BALPA running a campaign would be a good start.
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As far as EASA is concerned, the UK is solidly behind the IMC Rating - either retaining it just in the UK or grandfathering its privileges into something pan-European.
The problem is some other European countries, notably France and Germany. Over there, objections have come from airline pilots, their unions, and their national CAAs. However, none of these objections are based on any evidence whatsoever - they are merely adopting a "there must be no flight in IMC without an IR" position.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
The task ahead is to come up with good safety data which can be used to convince these people, and IMHO this isn't going to be too hard because the evidence is clear: there have been thousands of IMCR holders flying on it for decades and there is very close to zero evidence of any of them having accidents attributable to the exercise of the privilege. On the scale of statistics, it doesn't get much better than this.
Which is not to say it will be easy because blind prejudice is hard to work with.
The problem is some other European countries, notably France and Germany. Over there, objections have come from airline pilots, their unions, and their national CAAs. However, none of these objections are based on any evidence whatsoever - they are merely adopting a "there must be no flight in IMC without an IR" position.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
The task ahead is to come up with good safety data which can be used to convince these people, and IMHO this isn't going to be too hard because the evidence is clear: there have been thousands of IMCR holders flying on it for decades and there is very close to zero evidence of any of them having accidents attributable to the exercise of the privilege. On the scale of statistics, it doesn't get much better than this.
Which is not to say it will be easy because blind prejudice is hard to work with.
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Quote:
bose-x, that's not quite as I saw it!
not how Bose x saw it either!!!
bose-x, that's not quite as I saw it!
not how Bose x saw it either!!!
Agree with Beagle : let's concentrate on the issues, not on each other, eh ?
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Thanks FF, at least you took the time to read the post rather than just looking for a childish reason to fight with me.
As far as IO's view is concerned, it is exactly what I have been saying all along, the UK is behind the IMC the rest of Europe is not and it is they that needs to be convinced. I have seen nothing yet put forward that if playing devils advocate I was European would convince me.
As I have said before the safety case is an interesting angle, how do you make it stack up when the rest of Europe (with the exception of the French) seem to get on quite fine without it. Our weather is not unique, look at Ireland and and the western coast of Europe.
I really do think that the plan of action should be to get a permanent difference filed and leave it at that.
As far as IO's view is concerned, it is exactly what I have been saying all along, the UK is behind the IMC the rest of Europe is not and it is they that needs to be convinced. I have seen nothing yet put forward that if playing devils advocate I was European would convince me.
As I have said before the safety case is an interesting angle, how do you make it stack up when the rest of Europe (with the exception of the French) seem to get on quite fine without it. Our weather is not unique, look at Ireland and and the western coast of Europe.
I really do think that the plan of action should be to get a permanent difference filed and leave it at that.
Last edited by S-Works; 23rd Jan 2008 at 09:06.
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Do figures exist which show a marked disparity in IMC-related accident rates between IMCr holders and non-holders ? Or how about between holders and the non-IR PPL population in Europe ?
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Originally Posted by IO540
...they are merely adopting a "there must be no flight in IMC without an IR" position.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
[This isn't an excuse to tell everyone how great the FAA IR is, it is a genuine question about the difference in views between France/Germany and the US...]
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It's obviously not a genuine Q rustle but I will answer it anyway.
The context is completely different.
The FAA IR is much more achievable than the JAA IR.
But then if Europe did not have its stupidly gold plated IR, increasingly gold plated over the past decades, and had improved the utility of GA with things like GPS approaches as soon as these became so obviously proven elsewhere, especially ones without on-field ATC, the present mess would not be such a mess.
Policymaking should be evidence based. There is ample evidence the IMCR is working well and has done so for decades. There is NO evidence against it.
A separate approach is to dump the IMCR and push for a "reduced IR". This is favoured by many - mostly Euro IR holders who got their IR many years ago - and is an objectively reasonable view. Unfortunately, the politics of that are just as hard, and additionally if this came about in any form that is actually likely in Europe (i.e. still a substantial ground school increment over the FAA version) we would not have the uptake which the IMCR has, not by a very long way.
The best solution for the UK is to work out some sort of UK-only exemption. I don't think it is impossible. But there isn't a formal mechanism for "filing a difference to EASA".
The context is completely different.
The FAA IR is much more achievable than the JAA IR.
But then if Europe did not have its stupidly gold plated IR, increasingly gold plated over the past decades, and had improved the utility of GA with things like GPS approaches as soon as these became so obviously proven elsewhere, especially ones without on-field ATC, the present mess would not be such a mess.
Policymaking should be evidence based. There is ample evidence the IMCR is working well and has done so for decades. There is NO evidence against it.
A separate approach is to dump the IMCR and push for a "reduced IR". This is favoured by many - mostly Euro IR holders who got their IR many years ago - and is an objectively reasonable view. Unfortunately, the politics of that are just as hard, and additionally if this came about in any form that is actually likely in Europe (i.e. still a substantial ground school increment over the FAA version) we would not have the uptake which the IMCR has, not by a very long way.
The best solution for the UK is to work out some sort of UK-only exemption. I don't think it is impossible. But there isn't a formal mechanism for "filing a difference to EASA".
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Originally Posted by IO540
It's obviously not a genuine Q rustle but I will answer it anyway.
The context is completely different.
The context is completely different.
I support most of the various initiatives to maintain the IMC rating, but I don't think sidestepping questions about posts on here helps: If you're going to write things like
Originally Posted by IO540
...they are merely adopting a "there must be no flight in IMC without an IR" position.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
Obviously, to any thinking person, such opposition appears ridiculous as it is clearly based on blind prejudice and ignorance.
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rustle:
The question you've posed to IO540 is a very, very good one, and its answer may well be a pointer to how this IMCR issue pans out.
So, perhaps you would like to advise us as to how the various UK GA representatives should best address the question!
To do so impressively would remove any lingering doubts that many on here may have as to your actual feelings (such as "I've got an IR so I couldn't give a stuff"!).
There's value in posing the difficult questions, no doubt.
But providing credible answers is what really counts. Can you?
The question you've posed to IO540 is a very, very good one, and its answer may well be a pointer to how this IMCR issue pans out.
So, perhaps you would like to advise us as to how the various UK GA representatives should best address the question!
To do so impressively would remove any lingering doubts that many on here may have as to your actual feelings (such as "I've got an IR so I couldn't give a stuff"!).
There's value in posing the difficult questions, no doubt.
But providing credible answers is what really counts. Can you?
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The comparison with the USA, with its very different aviation scene, and its IFR privileges which are well integrated into its culture at all levels from low end GA to ATP level and whose achievability or syllabus are practically never even discussed let alone questioned anywhere on the vast U.S. aviation scene, makes for a funny and apparently provocative one-liner question on Pprune (and which really should thus have been posted on Flyer instead) but it doesn't help to work out a way to convince a number of traditional European aviation professionals that the skill set required to fly in IMC is nothing like the gold standard which they have spent their lives guarding.
A lot of it is down to personal experience. The people who object to any form of reduced-content IR (let's forget what one should call it for now) tend to be people who don't actually fly GA IFR. And many don't fly at all.
Even on pprune, it's dead easy to spot those who don't fly, from the stuff they write (or, more accurately, don't write).
The same is probably true for airline pilot bodies and airline pilot unions. There may be some active pilots among them but there are a couple of reasons why these people will have little or no GA IFR experience.
Firstly, if an ATP does fly for leisure, the last kind of flying he will be doing will be IFR. Ask any syndicate / timeshare setup how many serving ATPs they have as members. Most ATPs are a bit sick of IFR. For leisure, they fly rag and tube types. 100.000% VFR and on CAVOK days.
Secondly, GA of any sort and particularly IFR GA, is pretty thin in most of Europe. The UK is busy, Germany less so, France a lot less so, and the rest of Europe has relatively hardly any activity. By the time you get down to Greece you are looking at (of the order of) 200 GA planes - about 1% of the UK fleet.
This is why, as I have written many times, if you fly from say UK to Croatia, you might see 10 planes on a short leg in the UK but by the time you are in France the airspace is empty and then it gets even more empty. By the time you reach the Alps there is almost nobody "GA" on the radio. There are probably a few thousand IFR diehards zooming around Europe but even if each of them did 200hrs/year you would rarely meet one. Getting the full IR has been just too hard for too long.
So, taking Europe as a whole, there is going to be very very very little experience of GA touring among the people engaged in aviation professionally.
So it's no wonder that they don't understand.
And remember this is the same problem for both the "Euro IMC" and any reduced-content IR. Both of these initiatives are well stuck as a result. I wouldn't like to guess which is more stuck. Obviously the degree to which the IR is stuck depends on how much of the gold plating you want to take off - a recent 25% strip-off took ages and still got stuck. A "Euro IMC" is well stuck at the very start because it goes to the heart of the matter right away.
One could have a fun strategy debate which of the two is best worked on to un-stick it, but one thing is certain:
A "Euro IMC" would get picked up by a large % of pilots around Europe. Anecdotal evidence suggests the French and German PPLs would absolutely love it; especially German (and German-speaking) ones who do a lot more touring than the French. Whereas a "reduced IR", say 50% reduced ground school, would still be starting as an "IR", be taught by the professional schools, be examined by the professional pilot examiners, be fully ICAO and require the full JAA medical, and is never going to have much of a take-up. The yardstick for the likely take-up of any plausibly chopped-down IR would be the FAA IR takeup in Europe - at a guess, looking at IFR tourer sales, ~ 100 per year. The UK-alone historical IMCR takeup is 3x that!! The FAA IR takeup is of the order of 10x of the JAA IR takeup but that doesn't mean much because the JAA takeup is so close to zero (single digits/year in the UK, once you exclude the ATP pipeline crowd).
I don't know the answer. EASA does want to push an "IMC privilege" for PPLs and has done from day 1, more or less. If they didn't, you could forget it and an IR would be the only game in town.
It's all politics, so it's quite possible that the pressure to accept a low level IMC privilege (note: the name "IMC Rating" is a bit of a dirty word in Euro regulatory circles, alongside "FAA") may in fact ease in a substantially different IR.
Australia has an IMC privilege, done as modules. The 1st one gives you IMC enroute only (SRA is the only non-mayday IMC landing option). The next one gives you approaches, or something like that. Eventually you can reach an ICAO IR. This is a good way forward - so long as the VFR-only GA lobby don't screw it up again.
The future will be interesting.
A lot of it is down to personal experience. The people who object to any form of reduced-content IR (let's forget what one should call it for now) tend to be people who don't actually fly GA IFR. And many don't fly at all.
Even on pprune, it's dead easy to spot those who don't fly, from the stuff they write (or, more accurately, don't write).
The same is probably true for airline pilot bodies and airline pilot unions. There may be some active pilots among them but there are a couple of reasons why these people will have little or no GA IFR experience.
Firstly, if an ATP does fly for leisure, the last kind of flying he will be doing will be IFR. Ask any syndicate / timeshare setup how many serving ATPs they have as members. Most ATPs are a bit sick of IFR. For leisure, they fly rag and tube types. 100.000% VFR and on CAVOK days.
Secondly, GA of any sort and particularly IFR GA, is pretty thin in most of Europe. The UK is busy, Germany less so, France a lot less so, and the rest of Europe has relatively hardly any activity. By the time you get down to Greece you are looking at (of the order of) 200 GA planes - about 1% of the UK fleet.
This is why, as I have written many times, if you fly from say UK to Croatia, you might see 10 planes on a short leg in the UK but by the time you are in France the airspace is empty and then it gets even more empty. By the time you reach the Alps there is almost nobody "GA" on the radio. There are probably a few thousand IFR diehards zooming around Europe but even if each of them did 200hrs/year you would rarely meet one. Getting the full IR has been just too hard for too long.
So, taking Europe as a whole, there is going to be very very very little experience of GA touring among the people engaged in aviation professionally.
So it's no wonder that they don't understand.
And remember this is the same problem for both the "Euro IMC" and any reduced-content IR. Both of these initiatives are well stuck as a result. I wouldn't like to guess which is more stuck. Obviously the degree to which the IR is stuck depends on how much of the gold plating you want to take off - a recent 25% strip-off took ages and still got stuck. A "Euro IMC" is well stuck at the very start because it goes to the heart of the matter right away.
One could have a fun strategy debate which of the two is best worked on to un-stick it, but one thing is certain:
A "Euro IMC" would get picked up by a large % of pilots around Europe. Anecdotal evidence suggests the French and German PPLs would absolutely love it; especially German (and German-speaking) ones who do a lot more touring than the French. Whereas a "reduced IR", say 50% reduced ground school, would still be starting as an "IR", be taught by the professional schools, be examined by the professional pilot examiners, be fully ICAO and require the full JAA medical, and is never going to have much of a take-up. The yardstick for the likely take-up of any plausibly chopped-down IR would be the FAA IR takeup in Europe - at a guess, looking at IFR tourer sales, ~ 100 per year. The UK-alone historical IMCR takeup is 3x that!! The FAA IR takeup is of the order of 10x of the JAA IR takeup but that doesn't mean much because the JAA takeup is so close to zero (single digits/year in the UK, once you exclude the ATP pipeline crowd).
I don't know the answer. EASA does want to push an "IMC privilege" for PPLs and has done from day 1, more or less. If they didn't, you could forget it and an IR would be the only game in town.
It's all politics, so it's quite possible that the pressure to accept a low level IMC privilege (note: the name "IMC Rating" is a bit of a dirty word in Euro regulatory circles, alongside "FAA") may in fact ease in a substantially different IR.
Australia has an IMC privilege, done as modules. The 1st one gives you IMC enroute only (SRA is the only non-mayday IMC landing option). The next one gives you approaches, or something like that. Eventually you can reach an ICAO IR. This is a good way forward - so long as the VFR-only GA lobby don't screw it up again.
The future will be interesting.
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I have what I hope is a credible answer. The UK files a difference and leaves it at that. We don't try and get the IMC extended to Europe, we don't try and turn it into a mini/poor mans IR. We just leave it alone.
Credible enough?
Credible enough?
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It should not be forgotten that it was widely reported by a few that:
the IMC rating was dead,
there would be no grace years,
it could have no place in EASA FCL
a national exception could not be filed
their would be no wider adoption of the rating
the lack of support from the rest of Europe would be insurmountable
None of these reports have yet proven correct.
That suggests to me that the campaign at www.ukimc.org has been useful together with the work done by those representative bodies in favour of retaining the IMC rating.
The support for the campaign has been over whelming.
I am in no doubt from the testimonies and comments we have received the vast majority of us are convinced of the importance of retaining the rating.
Over the coming weeks there will be more evidence to support the retention of the IMC rating. I believe that the evidence will be persuasive that there is a case for its wider adoption throughout Europe.
It is clear that the CAA support the rating.
It is clear that the statistical evidence presented at the press briefing would leave very few to doubt the proven safety record of the rating.
It is understandable that because many in Europe have no experience of the rating, they must rely on us demonstrate the ratings proven record in the UK
It is now for all the representative bodies, and for all of us, to rise to the challenge of ensuring the case is stated because I am in no doubt the evidence will ultimately prevail.
Please support the campaign, register your support at www.ukimc.org, and let us know if you are willing to lend your expertise to the campaign.
I believe it should be restated how this issue has progressed lest we fail to appreciate what has laready been achieved.
That said we believe we have a very good case for its retention in the UK.
I believe in what EASA are seeking to achieve. I am not going to be so disingenuous as to suggest that whats good enough for us is not good enough for the rest of Europe. We totally believe in the case we have, it is up to us to sell it to Europe.
I find it interesting that when I talk to pilots from Europe and to their organisations their intial reaction is exactly as would be expected. However, take time to explain how the IMC rating works, how pilots in the UK use the rating and set out the safety evidence that has already been well recited and they want what we have!
It is up to us to take the message to the rest of Europe - I think we will be pleasantly surprised by their reaction if we make a good job of it rather than bickering between ourselves.
the IMC rating was dead,
there would be no grace years,
it could have no place in EASA FCL
a national exception could not be filed
their would be no wider adoption of the rating
the lack of support from the rest of Europe would be insurmountable
None of these reports have yet proven correct.
That suggests to me that the campaign at www.ukimc.org has been useful together with the work done by those representative bodies in favour of retaining the IMC rating.
The support for the campaign has been over whelming.
I am in no doubt from the testimonies and comments we have received the vast majority of us are convinced of the importance of retaining the rating.
Over the coming weeks there will be more evidence to support the retention of the IMC rating. I believe that the evidence will be persuasive that there is a case for its wider adoption throughout Europe.
It is clear that the CAA support the rating.
It is clear that the statistical evidence presented at the press briefing would leave very few to doubt the proven safety record of the rating.
It is understandable that because many in Europe have no experience of the rating, they must rely on us demonstrate the ratings proven record in the UK
It is now for all the representative bodies, and for all of us, to rise to the challenge of ensuring the case is stated because I am in no doubt the evidence will ultimately prevail.
Please support the campaign, register your support at www.ukimc.org, and let us know if you are willing to lend your expertise to the campaign.
I believe it should be restated how this issue has progressed lest we fail to appreciate what has laready been achieved.
That said we believe we have a very good case for its retention in the UK.
I believe in what EASA are seeking to achieve. I am not going to be so disingenuous as to suggest that whats good enough for us is not good enough for the rest of Europe. We totally believe in the case we have, it is up to us to sell it to Europe.
I find it interesting that when I talk to pilots from Europe and to their organisations their intial reaction is exactly as would be expected. However, take time to explain how the IMC rating works, how pilots in the UK use the rating and set out the safety evidence that has already been well recited and they want what we have!
It is up to us to take the message to the rest of Europe - I think we will be pleasantly surprised by their reaction if we make a good job of it rather than bickering between ourselves.
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bose-x said:
If it were a long-term sustainable position, I for one would say that would be a very creditable result, albeit second best to a European-wide equivalent. But...
1. AOPA's notes of the meeting suggest that this solution is also subject to approval by people that are against the rating and is therefore problematic; and
2. it is no more a credible answer (or, for that matter, any answer) to the question rustle posed IO540 than was IO540's ... and rustle said that his was an unhelpful sidestepping of the question (I'm sure he'll be along in a minute to say the same to you).
I have what I hope is a credible answer. The UK files a difference and leaves it at that. We don't try and get the IMC extended to Europe, we don't try and turn it into a mini/poor mans IR. We just leave it alone.
Credible enough?
Credible enough?
1. AOPA's notes of the meeting suggest that this solution is also subject to approval by people that are against the rating and is therefore problematic; and
2. it is no more a credible answer (or, for that matter, any answer) to the question rustle posed IO540 than was IO540's ... and rustle said that his was an unhelpful sidestepping of the question (I'm sure he'll be along in a minute to say the same to you
).
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To reiterate my earlier comment it is clear to me we are convinced of the case for the IMC rating. The CAA are convinced. EASA would seem persuaded. BALPA support the rating.
Are we that disingenuous to our fellow pilots in Europe as to not at least seek to convince them of the merit of our case?
Do we truly believe that they are against the rating for the reasons regurgitated on here by a few?
Or might it be because we have not taken the trouble to properly present the case and the evidence?
After all we now have at least four years in which to do so!!
(Edited to add in so far as Rustle's question is concerned, and I am NOT making this comment to be argumentative, I didnt understand the question, so for those that did perhaps you could spell it out if it has not now been answered).
Are we that disingenuous to our fellow pilots in Europe as to not at least seek to convince them of the merit of our case?
Do we truly believe that they are against the rating for the reasons regurgitated on here by a few?
Or might it be because we have not taken the trouble to properly present the case and the evidence?
After all we now have at least four years in which to do so!!
(Edited to add in so far as Rustle's question is concerned, and I am NOT making this comment to be argumentative, I didnt understand the question, so for those that did perhaps you could spell it out if it has not now been answered).
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ukimc.org
I notice that the http://www.ukimc.org/news.html has been updated and now includes a very comprehensive write up from yesterday's CAA / EASA press briefing.