IMC rating recommended minima?

[IO540]

I am going to stick my kneck out here and say that I feel trying to defend the IMCR my be counterproductive.

In terms of political expediency, I would agree. But what is an "IMCR"? Let's not get emotionally attached to the name. It is no more than an IFR privilege in Class D-G, which world peculiarly well in the UK where most CAT is in Class A and which has a near totally partitioned IFR service which does not have to provide any service to IMCR holders. One could develop a similar privilege for some other countries; for example it would work well in France and its extensive Class E. This is not lost on some people looking into this. The stumbling block is the emotional and professional/status attachment to the IR.

Really what everyone appears to want is an achievable PPL IR Simular to the FAA variety.

True, and everybody knows this. Everybody in EASA knows it too, right up to the very top (I happen to know 1st hand). But the politics........

However the overall picture is more complicated. The "FAA scene" is largely about the FAA IR but not wholly. There are certification issues, especially to do with mods, and while these are politically far easier to deal with, they will take time and some areas, e.g. FAA field approvals under 337s, are emotionally grating to European inspectors.

Both the IMCR and the impractability of getting an IR for Joe Blogs in the street could be challenged in the European courts on the grounds of being denied safety in an unreasonable way.

I wish you were right. You might be, but I doubt it. If you were right, however, the medical requirements would be vulnerable to an attack under European disability laws - basically, any requirement not meeting the test of demonstrated competence would get overturned. Great, eh? I am sure somebody has tried this (and failed) in Europe though. Pape in Australia did it on colour vision and won, but his victory is sub-ICAO. It took him years, too.

I also don't think that an "overly hard IR" can be challenged on safety grounds - much as I wish it should be. Because there is the VFR option, and this can always be used to undermine any safety argument. The VFR option is great because it enables the regulators to wash their hands of practically everything. "We did teach you to remain clear of cloud" will always be a good defence.

There was a major study carried out on the comparisons between FAA and JAA licening.
The result was that there was NO difference in safety between JAA trained pilot right up to ATP and the FAA trained pilots.

Of course.

Trying to defend the IMCR might get a result on grounds of safety as there is plenty of evidence showing the french high accident statistics with pure VFR only compared to the UK IMCR protected pilots.

But following safety lines might mean you end up getting an IMCR to be used only for inadvertant entry into IMC and with the declaration of a mayday.
Not what I think we want to achieve.

Not sure why you think that. There is no way to define "inadvertant entry into IMC". Privileges can only ever be tied to pilot paperwork and airspace class (or area e.g. the LTMA). And with a mayday all bets are off anyway - your aunt could declare a mayday and be 100% legal.

Better to go for an FAA type PPL IR with a direct challenge on the grounds of safety to the European Courts claiming the present system is not achievable in a practical way for working people and endahgering their lives by not having it.
As stated there are plenty of studies showing that FAA and JAA achieve the same standards albeit by different routes and in safety too.

It might be cleverer to abandon the IMCR and concentrate on an FAA like PPL IR. dont shoot yourselves in the foot.
Finally abandon the reason way through normal channels and go to court to force it through.

A lot of people (including some sensible ones) think that pushing for an acceptance of FAA stuff is a lost cause - because of the massive emotional attachment to "the European way" which "must" be different to the American way. And thus bringing in a reasonably accessible "private IR" is the way to go.

I think this will probably happen in years to come because it is the politically least-resistant path.

I just hope they don't screw it up. If the average N-reg costs £20,000 to transfer to G-reg (or some other EASA reg - don't for a moment think that a forced transfer will result in every UK based plane automatically going on G-reg) that will make any Euro IR a waste of time. The current EASA attitude to some mods is really anal - I could PM you some ludicrous cost examples.

One thing is for sure: nobody will know what is going to happen for a few years.

And in the meantime, it is not beyond the possible that some countries could push through a sub-IR privilege. It does, after all, have the public backing of EASA.

Fuji

if it is confidential then it is best to say nothing. Just my opinion you understand.

I agree - there has been too much on here pretending to be leaks from committee proceedings, and I don't think much of it was true, or relevant.

[Fuji Abound]

In terms of political expediency, I would agree. But what is an "IMCR"? Let's not get emotionally attached to the name. It is no more than an IFR privilege in Class D-G, which world peculiarly well in the UK where most CAT is in Class A and which has a near totally partitioned IFR service which does not have to provide any service to IMCR holders.

IO - a very well reasoned post and excellent reading.

One point on which I would expand that caught my eye in your comment above.

Many people seem obsessed about IMC outside CAS in rubber band jobs. Horrified at all these dangerous IMC rated pilots occupying airspace in cloud. However, lets pause for a moment. More pilots kill themselves in the UK in VMC than IMC rated pilots in IMC. Does that mean the basic training is inadequate?

For those IMC pilots that do kill themselves in IMC, what risk do they pose? Regulators have a duty to protect the innocent - I am not sure they have a duty to protect us from ourselves. A rock climber can climb a pitch beyond his ability. A yachtsman can sail into a super tanker in fog without an instrument rating.

A bit off beat I know, but where is the evidence that IMC rated pilots outside CAS are a risk to the public?

I appreciate they are entitled to carry passengers and the regulator has a conceivable responsibility to their passengers. However, as I said earlier, I reckon a passenger is safer with an IMC rated pilot than a non IMC rated pilot.

Aviation is obsessed with regulation and so are we all. There are times to stand back from the regulation and question whether the regulation has purpose, whether the regulation is seeking to protect us from some unfound and unrealised threat, and if it is, in doing so, does it cause a bigger risk in itself (as is the case in France where far more pilots kill themselves in IMC).

[IO540]

where is the evidence that IMC rated pilots outside CAS are a risk to the public?

There isn't any such evidence.

Even EASA has stated in one of its tomes that it recognises the 3rd party risk in GA is insignificant.

And to add to the mix, the French have a fairly robust attitude to pilots killing themselves anyway ("it's a risky hobby, what do you expect") and the French practically own EASA, don't they?

So I think the future could be interesting.

The one reasonable reason for ditching the IMCR and driving for a more reasonable private IR, is based on the dilution of the obviously limited resources of any one campaign group. Again, political expediency, though understandable.

But if one wanted to push for some kind of IMCR outside the UK, one wouldn't campaign head-on through the committee system. That would be completely totally futile - look at how far the IR has got in that pipeline (almost nowhere). The way to do it would be to do a grass roots campaign and get large numbers of pilots hassle their own national bodies. Most non-UK PPLs make it clear they would give their arm and a leg for an IMCR in their own country.

[Johnm]

This thread seems to have drifted onto the "let's have a private IR in Europe" topic which I whole heartedly support and I agree that a combination of national AOPAs and national CAA might well swing it and so we should all be pushing our colleagues down that road.

The fundamental problem though is what happens if some t0$$er decides to try to WITHDRAW existing privileges by cancelling existing IMCRs?

[IO540]

The UK IMCR is here to stay until c. 2012.

The CAA has stated they will apply to the EU for an extension after that, using some provision the name of which escapes me. I went to the CAA/EASA presentation in London on this topic.

After this, nobody knows.

There is a theoretical possibility that a political solution may be found for grandfathering the IMCR privileges into something else which may be developed by then.

The history of aviation paperwork suggests that simply stripping pilots of some privilege - especially an important safety related one - rarely if ever happens.

[Fright Level]

And don't forget all the "hidden" IMC ratings attached to all UK ATPL holders licences.

[cambridge]

Single Crew Minima.

Can anyone clarify the minimum RVR required for a legal single pilot PUBLIC TRANSPORT ILS approach. Do different states have different minima?

[IO540]

According to the AOC, surely?