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Where are we really going with the IMC rating?

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Old 6th Feb 2008, 16:46
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Where are we really going with the IMC rating?

I thought, since I started it here I should post here to keep the IMC rating in the headlights and make it clear that we need everyones continuing support with our campaign.

It is very easy to think the battle has been won, when so far there has only been a minor skirmish.

On the positive side, it would seem EASA will protect the IMC rating during a transition period of up to four years, from 2008.

On the negative side, the survival of the IMC rating will ultimately depend on the degree of support for the rating here and in the rest of Europe.

Unfortunately, it is far from clear what position each of the UK representative organisations take on this matter. Sadly, their web sites contain very little information on which we might form a view. They have represented us during the early committee stages but a veil of secrecy has been drawn over those meetings. Many people have asked for copies of the minutes, or at least a summary, but nothing has been forthcoming.

You might expect to a man they would support the European wide retention of the IMC rating, given the view of the vast majority of British pilots. However, if they do, they certainly have not been very quick to nail their colours to the mast. This, in my opinion, is a great shame. We would all be better served if we could co-operate on such a key matter.

Whatever happened to open representation?

There is a growing suspicion that some of the representative organisations are selling out the IMC rating in the belief that a more acceptable IR is achievable.

Unfortunately this presupposes that most pilots want to commit time and money to an IR, when the IMC rating already provides everything they need.

Moreover, the evidence is that any “concessions” in the IR syllabus will comprise little more than tinkering with the theory content, and would in any event presumably result in a two tier system divided between the "commercial IR" and the “private IR”.

There is a growing suspicion that the representative organisations think they know what is good for us, but forgot to ask us along the way.

Now I fully appreciate it will appear that I am running them down and ignoring all the work they do for us.

That would be wrong.

I am concerned that in this process none of us make any assumptions. It would be a great shame to believe our representative bodies support our own view on this issue when they hold another.

It seems not unreasonable that we should know how we are being represented, so that we can make intelligent choices about whether we agree with the way we are being represented.

My concern extends to the rest of Europe as well.

It is widely reported the French are opposed to the IMC rating.

It is widely reported the European Commercial Pilots Association is opposed to the IMC rating.

Why is the average French pilot opposed? I don’t know the answer. I am not even certain anyone has asked them. Are they opposed because no one has bothered to explain the rating to them?

The CAA say that there is no evidence what so ever of problems associated with IMC rating pilots mixing with commercial traffic. Does the European Commercial Pilots Association know better? In fact I have written to their secretary on three occasions to ask them to set out their position. I have yet to receive the courtesy of an acknowledgment of my correspondence, never mind an informative reply. Does this mean that they are above the democratic process? Does this mean if their own members write to them they will also not be given the privilege of a reply? Perhaps some one on here who is a serving commercial pilots might like to try? Who in fact do they actually represent?

Why would you pay good money for someone to represent you and not have a clue whether they are representing your views or their own? BALPA say they support the IMC rating - good news indeed. Are they really a lone voice in the rest of Europe's commercial world? Is the commercial world so blinkered as to not examine over forty years of evidence gathered in the UK or has no one bothered to provide them with the evidence?

Lots of questions unanswered.

So far as our campaign is concerned, we are going to try an get some answers. We are going to try and honestly engage anyone and everyone.

Very shortly we will be “rolling out” our new web site, which will be carried in a number of other languages. We are going to work hard on continuing to drum up support here and in Europe. We have one or two other initiatives that we think will be helpful.

For the time being please continue to register with the campaign at www.ukimc.org

I apologise for the long post.

However, there is a very real danger we each and everyone don’t support the campaign through lack of time or because we fell we can leave it to others. If you believe in preserving the IMC rating which is all that we stand for, we need your support. If you are clear on the position of any of the representative organisations to which you may belong by all means give them your support as well and ask how you may demonstrate your support.

You can support our campaign by simply registering on our web site. We will suggest to you when it is a good time to contibute further as matters progress through the consultation phase.

For the avoidance of any doubt our campaign is solely concerned with preserving the IMC rating in the UK and for its wider adoption by EASA. We are not in the business of compromise - and the loss of the IMC to be replaced with some other form of IR is not on our agenda.

Finally, I am aware there has been some criticism of “our” No 10 petition. The petition has demonstrated the extent of the support. I believe this was needed. I accept there is a danger that those who have signed don’t now support the campaign. That is one further reason for my asking now for you to register to with us.

Last edited by Fuji Abound; 6th Feb 2008 at 17:10.
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Old 7th Feb 2008, 07:22
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IMCR Misbehaviour

Hi Fuji,

Let me say at the outset that I am in favour of the IMCR and want to see it retained.

However, within recent days we have all read the posts by a French ATCO who had personally handled a number of instances where IMC holders had quite illegally entered French airspace in serious IMC and had then become a serious problem for French air traffic control staff by reason of lack of skill, currency or judgement. She was adamant that she wished to see the IMCR scrapped, and as soon as possible.

Unfortunately, although French ATCOs do report the actions of these people to the French authorities, somehow this has not resulted in contact between DGAC and CAA with a view to prosecution, so the misbehaviour has continued.

Under these circumstances, it is surely no surprise that the French at least are against the IMCR. We have no way of knowing how these same people behave in other countries of the JAA participating countries. Perhaps these people are doing the same thing in Spain, Belgium, the Netherlands and elsewhere. So no wonder other countries are against the IMCR.

If we want to get other countries to support the IMCR, then this needs to be the first thing we attend to, as even the best of campaigns such as your own are going to fail if our own people are, in effect, 'shooting us in the foot'.

If the IMCR is to achieve support from other countries, then the holders of the rating have got to secure a reputation for being both competent and responsible.

Broomstick.
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Old 7th Feb 2008, 07:55
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Broomstick - I can assure you that anything serious notified to the DGAC does get pursued back to the UK. A few years ago I busted a TRA in France (in the days when the French IGN charts did not yet show their nuclear power station TRAs, and the ais.org.uk notam system did not yet carry the info either). I was under radar contact with a special squawk issued; French ATC said nothing at the time but asked me for the pilot name, his inside leg measurement, etc. 6 months later I heard from the CAA who were asked to prosecute on behalf of the DGAC. The radar trace (which I got a copy of) proved the special squawk and made everybody wonder why ATC did not tell me about it at the time but that is another story...

So I think if we did see the alleged huge numbers of Brit pilots flying illegally in France, there would be a lot of cases heard of over here of people getting done. The GA rumour mill would make absolutely sure of it. Yet, nothing, zero, zilch has been heard. I reckon that if some cases were suspected there was no proof and no action was taken.

It takes only a few cases of French police pick on an N-reg pilot and turn his plane over checking his VAT certificate and the words "instrument pilot" on his plastic card, for the word to get right around.
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Old 7th Feb 2008, 08:02
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Would the French still be against an IMC rating (to keep it's old name) even if it were valid in France? Surely this would eliminate supposed problems of people illegally using an IMCr in France. I wonder how may incidents out Irish neighbours get?

Despite what some short sighted people think, the no. 10 petition does one thing really well.....acts as a key indicator to everyone what level of support the IMCr has. I don't really care if Gordon B writes back a standard "of course we will review this..." letter, becuse it lets us know what the PEOPLE think.

Of course if the "people" can't be arsed with the IMCr then that is another matter. I suspect also that no one has really asked the other European pilots if they want an IMCr...My mate is German and did the JAA PPL (UK) so he COULD add and IMCr to it.
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Old 7th Feb 2008, 08:17
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A sub-IR IMC privilege would work well in France.

Put a limit of FL110 on it, that keeps it below the major Class D base but would allow transit of the Class D airport zones.

Presently, VFR traffic is completely routinely allowed to pass through all this airspace which is for the most part devoid of traffic.

There are just a few mountainous areas where FL110 would not be enough, but not many.

And FL110 is a reasonable level for which (or below which) one could file meaningful IFR flight plans.

Mode S would be mandatory of course, together with BRNAV above FL095.
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Old 7th Feb 2008, 08:55
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One voice !

There is nothing that a goverment department likes more that an industry that speaks with more than one voice, they use this as an excuse to do nothing by saying that they are getting mixed messages from the industry.

So what ever happens if the IMCr is to be saved then ALL of UK GA must speak with one voice on the subject.

Personaly I think that the IMC is doomed because a "not invented here" attitude seems to persist in EASAland but as a tool to get a Europe wide class two IR the current campaign is in the forefront of putting pressure on EASA to act on this issue that they want to leave on the back burner.

The work that is being done to save the IMCr has my full support and I will be writing to my MEP but the thrust of my letter will be to in effect extend the IMCr to the whole of Europe, on safety grounds alone this is a good idea but I know that to sell it to the other states in Europe the name will have to change.

What I do find baffeling is the attitude of the European commercial pilots association, the safety issues are clear but still they stick to an intreched position dispite the evidence, unfortunatly this attitude is not suprizing to me at the moment in the UK motorcycle groups are campaigning to use bus lanes on safety grounds, reseach has shown a dramatic drop in accidents (45% drop in motorcycle /pedelcycle accidents) and yet it is the pedel cycle groups that are strongest opponents of motorcycles using bus lanes.

The only way to deal with groups with intrenched veiws is to keep using good reseach data and eventualy there position will become untenable.

Last edited by A and C; 7th Feb 2008 at 09:27.
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Old 7th Feb 2008, 11:07
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"A sub-IR IMC privilege would work well in France.

Put a limit of FL110 on it, that keeps it below the major Class D base but would allow transit of the Class D airport zones"


Precisely why I advocate referring to 'permitted' airspace for individual states to decide, rather than an universal one-size-fits-all decision imposed upon them!

We had this for military low level flying - the rules were different for Belgium, Holland and Germany. I once had a low level flypast to do in Belgium, but we had to approach from the east close to 'Dreilandenpunkt'. So 3 different sets of rules to adhere to in the space of 5 minutes! Not hard, just took careful preparation.
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Old 7th Feb 2008, 11:20
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ALL of UK GA must speak with one voice on the subject.
That is the problem...The reason Fuji started his campaign in the first place was because it was clear that GA was not talking with one voice.

I suspect some people in other organisations are not really interested in the IMCr as it may undermine their "available IR" campaign, and so don't want to become involved. The flying helmet and goggles brigade don't really care, and no one has asked our foreign neighbours their opinion...

The only way to speak with one voice as far as I can work out is to sign up to www.ukimc.org. It must be getting some weight behind it, when the CAA on asking some advice, advise you to visit this website for the answer!!!!
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Old 7th Feb 2008, 14:06
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It is widely reported the French are opposed to the IMC rating.
It is widely reported the European Commercial Pilots Association is opposed to the IMC rating.
Why is the average French pilot opposed? I don’t know the answer. I am not even certain anyone has asked them. Are they opposed because no one has bothered to explain the rating to them?
You have answered your own question there Fuji. About half the French pilots at my club here have heard of the IMCR, mostly because there is a Brit (me) who has spoken about it at their club!! When I have asked the active pilots who like to fly places (ie not the brevet de base type) most wish they could have one here in France as a Full IR is unatainable now.

So, to sum up : Alot of French PPLs probably havent heard about the IMCR and Im sure no-one has asked the French PPLs if they think its a good idea. I recall someone posting that UK-AOPA has been in contact with French AOPA, but I dont know anyone at our club thats heard of AOPA either - The FFA is the organisation representing PPLs here in France because all Club PPLs are members of the FFA in order to fly at aeroclubs!!

Regards, SD..
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Old 7th Feb 2008, 14:46
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Skydriller

Did you get my email in response to yours of a week or so ago?
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Old 7th Feb 2008, 17:24
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Some excellent points.

If we want to get other countries to support the IMCR, then this needs to be the first thing we attend to, as even the best of campaigns such as your own are going to fail if our own people are, in effect, 'shooting us in the foot'.
I agree.

However, I think equally we should be cautious of accepting the anecdotal comments of a single contributor. As IO540 comments it seems hard to believe if there are this many bad eggs DGAC and the CAA would not have taken more action. I can only reiterate IO540s comments that a friend of mine (it really was him not me!) infringed a military zone in France and he received his letter from the CAA within the week!

What I do find baffeling is the attitude of the European commercial pilots association,
I also agree.

However, their only members that are probably even remotely familiar with the IMC rating is BALPA. I suspect the real issue is that no one has bothered to properly put across the case to each of their members for the IMC rating. If we can get the grass roots support of GA in the main member states behind the rating they will in turn persuade their representative organisations of the wisdom of this campaign.

This is as much about education as anything else, something which I dont think any of our representative organisations have even considered.

It is all very well to have a 5 minute say at some committee meeting but as Skydriller comments if no one is a member of AOPA in France you might just as well stand on the end of Dover pier and shout, hoping that you might be heard the other side of the Channel.

Precisely why I advocate referring to 'permitted' airspace for individual states to decide, rather than an universal one-size-fits-all decision imposed upon them!
I am not convinced.

EASA want harmonisation - and rightly so!

We dont fly across America having to worry about the regulations changing just becasue we cross a line drawn in the sand. No more should we in Europe otherwise EASA is a waste of space.

I would forget all the old ideas - I think EASA fully intend to sweep that all aside from my idscussions with them and rightly so as long as they have the support of pilots who know what they want and can prove the safety case.

IMC rating access to all classes, except class A, and anythong below FL110 is simple to understand and ensures the minimium of interaction between CAT and GA. Moreover, with cross border radar services and hand offs in many parts of Europe I cant believe it helps the zone services either.
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Old 7th Feb 2008, 19:24
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It is beyond me as to why some pilots would deny themselves access to a poor mans instrument rating that has clearly been of great aid to private pilots that have this rating. It rises situational awareness and gives you a special get out of trouble card. The skills taught in the IMC rating are definitely very valuable and I know a couple of pilots that have used this rating to its full to act appropriate and safely in fast weather changing conditions. I know from a recent airfield meeting that the rating is safe for pilots that already have it for another 4 years, in which they will be allowed to practise the privileges of the rating but past that is deemed uncertain (information from the CAA). My flying club will still offer the IMC course after this point, even if it isn't a recognised rating, as they feel it is a great assest to a pilots skills/knowledge.
Perhaps people in these other countries, as someone has previously said, just don't understand what the IMC rating is nor what it can do for safe flying. Clearly EASA have safety in mind if they wish to bring in that French basic PPL were students can take passengers up at 20hours!! (where is the logic in this I ask you!?)
I've signed the petition and have forwarded it onto everyone I know.
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Old 10th Feb 2008, 15:41
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Fuji,

You have mail, Delayed due to work!!

SD..
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Old 10th Feb 2008, 16:10
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All this talk of educating the pilot population outside the UK who do not seem to know what the IMC rating actually does is a total waste of time.

The only people who you have to convince are the national aviation authorities and their representatives at EASA level plus a few pilot organisations. Convincing a pilot from Bordeaux will make no difference but if you can convince the French licensing officer then it is unlikely that French pilots are going to object.

Unfortunately, those people know what the IMC rating is and remember the JAR-FCL negotiations and why the IMC rating go it's special paragraph in JAR-FCL. One has to agree that any national aviation authority would have grave concerns with letting pilots having as little as 5 hours IMC flight training in the aircraft loose in their IFR system.

The CAA privately also can not see a way forward for the IMC with the future european airspace and IFR operation that is comming to the UK.

Statements saying that the IMC is a poor mans IR make the position worse.

The best way forward is to accept that the IMC rating is gone. Far better to work on a PPL-IR (a qualification suitable for flying IFR anywhere) and more importantly, credit for the IMC rating holders towards obtaining that IR.

Regards,

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Old 10th Feb 2008, 16:28
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There are 2 distinct camps developing:

1. Those who wish to keep the 15 hr UK IMCR, albeit called something else, and work to get it accepted by the rest of the EU.

2. Those who wish to kill off the UK IMCR and make the 50 hr IR somehow 'easier' to attain.

Well, sorry but I cannot fall in with the second camp. Who seem to be the well-off types of the PPL/IR world, in the main. The only real way forward with Europeans is to use their own rules back at them. Such as 'proportionality' of requirements....

IMCR/Class2IR and IR should have the same core IF skill requirements. Nothing to do with navaids or airways, I mean the basic stick and rudder skills to fly in IMC following ATC`instruction as required.

However, the rest of the training must be 'proportionate' to the needs of the end-user. So, for example, an FI, who just wants the IMCR privileges to climb up to VMC on top in order to teach basic lessons, does NOT need the same en-route training as the dedicated long distance IFR cruiser.

As for holders of other ICAO IRs? They should be accepted for direct conversion to EASA IRs with no formal requirements beyond issue fee and ICAO level 4 English.
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Old 10th Feb 2008, 16:58
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The only people who you have to convince are the national aviation authorities and their representatives at EASA level plus a few pilot organisations. Convincing a pilot from Bordeaux will make no difference but if you can convince the French licensing officer then it is unlikely that French pilots are going to object.
Unfortunately you are wrong.

In the UK there is hardly a pilot who would not like to see the IMC rating retained.

Most thought AOPA UK, PPL IR and the other rep. organisation would back them to the hilt.

We were all wrong on that count.

In fact the UK pilots have so far been backed by the UK IMC campaign (www.ukimc.org), the CAA and EASA - how is that for a turn up for the books.

EASA have fully taken on board the ground swell of support in the UK thanks to our campaign, all credit to them and the CAA for doing so.

In Europe the European Pilots Association didnt back the IMC. Why? Who knows, they dont reply to correspondence. BALPA support the IMC rating but they are only one member.

French pilots I feel want the IMC rating - they certainly do once they understand it.

So, Europe is a bit like here, the pilots will want the IMC rating once they know what it is about. Fortunatley many of the European pilots association will also want the IMC rating. They arent the problem. The issue is people like the EPA but if they dont even have the courtesy to reply to correspondence it will ultimately be us, the pilots, that let EASA know the IMC rating is a very good thing for Europe.
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Old 10th Feb 2008, 17:53
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I am currently working on an IMC use survey on behalf of AOPA. I will publish links to it here as soon as it goes live and would appreciate a link on the IMC campaign site.

No personal data is being collected. It will look the IP address to ensure there are no duplicate entries but otherwise will be looking at the type of flying, currency and status of IMC holders. This will enable us to build a proper case on the use and value of the IMC.

I would appreciate if this can be propagated in due course to the widest audience possible to facilitate accurate data collection.

I will post the official AOPA position on the situation shortly once I have had the wording approved.
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Old 10th Feb 2008, 18:03
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Bose

As per my post on Flyer we have already put together a survey which will also be concerned with the views of pilots in Europe - it is multi langauge and will come out with our new Euro web site.

You might like to share the data rather than asking everyone to complete two surveys - it would be far more productive.

We also have a really first rate web designer on the team.

www.ukimc.org
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Old 10th Feb 2008, 18:24
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I am more than happy to share data. We will still carry out our own survey as an AOPA initiative but cross validation will be beneficial.
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Old 10th Feb 2008, 18:36
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Bose

OK

Not looking to score points, but it is hardly an AOPA initiative, but as long as we achieve what we are seeking, who cares.

Given all the discussion on the AOPA forum

http://www.joinaopa.com/forum/viewto...er=asc&start=0

has AOPA actually decided what it is they are supporting?
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