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Should the IMCR be ditched in the quest for a greater prize?

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Old 19th Oct 2008, 12:36
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Should the IMCR be ditched in the quest for a greater prize?

I have started this thread as an extension of another thread which has developed into a debate on the IMCR and the desire for a easely obtainable PPL IR? I have placed it here under its own thread for discussion as I feel and hope it warrants more attention.

There are a number of pilots in that thread who are dedicated to maintaining the PPL IMCR and who are frustrated by the lack of movement by EASA towards a European acceptance of the IMCR.

Sometimes it is easier to see the wood for the trees If you are not deeply and emotionally involved in a cause.

knowing the History of Europe and its Burocracy and makeup I question the present direction in achieving anything worthwhile.
I also fear that trying to "save" the IMCR might be a bullet in the foot and counterproductive to the goal that posters are trying to achieve.

Infact saving the IMCR might just give EASA the way out it desires on a plate.

I will explain why!

Europe has always been different politically to the USA.
We border Russia and there has always been a more socialist burocratic tendency within Europe.

Call it state control, big brother intervention or whatever, but the Europeans have always been uncomfortable with the lack of control and freedom that GA has.

Europeans would much rather have all flying relegated to people carriers and all pilots trained to what they see as a "professional standard".

As in any profession they would like to structure the training around a university degree in aviation related matters and that is the big difference to the USA which takes a broader more practicle view of pilot licencing.

There was a major study on JAA V FAA pilots right up to ATP level.

The conclusion? That neither was better or safer than the other and both achieved the same goal of quality of ATP but following different routes.

The big problem with the IMCR is not the IMCR which can be proved by comparison with french VFR accident rates to save lives, but with what IMCR pilots have made it to be.

It has been made to be from its initial conception of a "get out of trouble" rating into a Mini Uk IR for getting around the UK in IMC conditions. Pilots who do not have the time or work allowance to spend months or years studying and passing mainly irrelevant exams to achieve a JAA IR use the IMCR for that end although it could never be promoted as an IR. Who Blames them as they have no real realistic other choice!

I have no doubt that if the CAA push hard enough we will get an EASA IMCR and give them a way out of ever offering the real deal of a EASA PPL IR.

Safety is the only guiding force which will achieve anything either in maintaining the IMCR or in getting a new PPL IR.

The safety statistics make the IMCR benefits indisputable but not in achieving what most want here.

I could easely see a situation where EASA might use the IMCR as a way of avoiding forming any Easely obtainable new PPL IR.

This is where the shooting in the foot bit comes.

10540 begged the answer to how you would define inadvertant flight into IMC conditions? That is EASY.

Inadvertant flight into IMC conditions is any flight by a pilot where for whatever reason he can no longer maintain VMC and hence navigation by sight and is forced into IMC where he can no longer navigate by sight or control the aircraft with visual reference to the ground or a horizon.
By that defininition any instrument training and nav aid training cannot be argued against and is a positive benefit to flight safety.

EASA could with little difficulty accept the IMCR on the grounds of safety but NOT in the way people want and by doing so eliminate any safety based arguement for a new JAA PPL IR.

They could accept it in its original form as a get out of trouble rating for VFR pilots and make it more restrictive than we have at present in the UK.

ie you can only use the rating in inadvertant entry into IMC conditions whereapon after the declaration of a mayday you will be radar vectored onto an ILS. But not to be used as a mini IR as is the case in the UK and what most want.

Agreeing to this new IMCR rating EASA could happily say we have allowed what you want and keep the status quo regarding any changes to the IR.

Hence my STRONG instincts would be to ditch saving the IMCR and put all my efforts through the European Courts on the creation of a more easely achievable PPL IR for NON professional pilots.

The grounds for that would be that EASA are putting pilots and their families/friends at risk by not allowing pilots who fly for business or pleasure the ability to achieve an IR in a practical way. They are dragging their heels motivated by internal political reasons rather than safety concerns which can be proved by statistical data and JAA V FAA comparison data. By doing so they are endangering pilots forced to attempt to fly VFR.

There is Loads of evidence both through VFR accident statistics in Europe and licence quality comparisons between FAA and JAA to make a successful challenge through the courts rather than the mindless ways through EASA.
EASA would then be forced to do something rather than empty promises, buying time and endless cups of tea and biscuits in a set in rock burocracy.

The Courts in my eyes are the only way forward without out chasing a dream for years ahead which will probably never materialise

Pace

Last edited by Pace; 19th Oct 2008 at 13:53.
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Old 19th Oct 2008, 12:59
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i have no views on the politics, but i would love a PPL IR which can be achieved in reasonable time for somebody in full time employment,

perhaps limited to below FL230, only precision approaches

With lower theoretical standards (cut the historical bullshot) but similar currency requirements to full IR (approaches and revalidation)
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Old 19th Oct 2008, 13:07
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i have no views on the politics, but i would love a PPL IR which can be achieved in reasonable time for somebody in full time employment,
But it is the Historic politics which is the brick wall against achieving anything for GA and hence the need to go above EASA to the European courts where something can be achieved and has been in other locked situations in the past.

Pace
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Old 19th Oct 2008, 13:15
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That would need to be done by a body such as AOPA then....

But to change their line of thought will require vision and guts
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Old 19th Oct 2008, 14:06
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The Courts in my eyes are the only way forward without out chasing a dream for years ahead which will probably never materialise
Pace which European Court are we talking about?
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Old 19th Oct 2008, 14:38
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I don't frankly think that we'd get anywhere in the european court; you could waste decades and millions of pounds and get precisely nowhere. As always with the law, whoever makes the case-law pays a very large bill indeed.

I do think that lobbying EASA will be the way forward, if only all the different bodies (PPL IR, AOPA, LAA etc.) could speak with one voice. At the moment we have a "Life of Brian" style situation with the Peoples Front of Judea vs. the Popular Front of Judea (splitters!!) - which suits the anti-GA lobby within EASA down to the ground. The sad truth is that all of these organisations are terrific bunches of guys, saying more or less the same thing, out of love of flying, rather than financial motivation.

I think that sacrificing the IMCR without a real world alternative (an achievable PPL/IR or a European version of the FAA PPL/IR) would be fatal and trying to get anything like an IR-lite set up post IMC abolition would be impossible. Rather akin to trying to find a job when unemployed, or trying to find a girlfriend when you're single

It would also be nice if there were some real support from the CAA on this front, but the sad truth about the CAA is three-fold;

1. The primary directive of the CAA is not to protect the interests of aviation or even regulate aviation (although it does so with varying degrees of success along the way); it's primary role is to make a sufficient margin of profit to remain in business. Change of any kind may threaten this cosy profitable world, and should be avoided.

2. There are still too many ex-military and retired commercial airline pilots populating the CAA, who dislike change intensely - just look at the complete lack of progress of GPS approaches (the underlying argument seeming to be that GPS is dangerous, but NDB's are safe) - and who continue want to do things as they have been done since the war; the "it was good enough for me, so it's good enough for them" argument. That is to say nothing about the chaotic and confused situation surrounding Part-M maintenance...

3. There is a very real paucity of political talent at the CAA is a terrific handicap to making any real progress within EASA. The state of open antipathy between EASA and the CAA is working against the interests of us pilots at the moment, and is likely to see us lose the IMCR (with no viable alternative on the horizon) and yet it is now pretty much certain that we will see a europe-wide roll out of the 'brevet de bas' because, according to EASA, the 'brevet de bas' is safe and good - but the IMCR is dangerous and bad.

Having roundly slated the CAA, I do know that there are some really good guys trying to bat our corner there, and perhaps now would be the moment for Bose-X to take a bow and let us know the latest??

Last edited by wsmempson; 19th Oct 2008 at 14:41. Reason: illiteracy
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Old 19th Oct 2008, 14:48
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Man, that was a long post!

In short, what you are saying is that a "PPL IR" would be more palatable to EASA as whole, and would be more advantageous for private pilots, compared to continuation of the IMCR.

If that's your point, I think it makes sense. Good reasoning.

In the meanwhile, my personal opinion regarding the status quo is that, yes, half the exams are totally irrelevant and it's not great value for the money. However, I disagree in that the current IR is particularly difficult to achieve.

It's expensive like everything in aviation and one must go and sit some exams, but each individual exam is no more difficult than sitting a driving licence theory test. There is just more of them, that's all.

I believe the theory part is perfectly doable in six months by someone working full time. By way of example, I did the full ATPLs in four months while working 80 hour weeks for two and a half of them. Not a huge lot of fun, but life wasn't that miserable either.

It would be interesting to hear from other JAR instrument-rated private pilots, to see what their experience was like.
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Old 19th Oct 2008, 14:57
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Hence my STRONG instincts would be to ditch saving the IMCR and put all my efforts through the European Courts on the creation of a more easely achievable PPL IR for NON professional pilots.
The problem is that there WON'T be any real alternative. If I thought that I could trade an IMCr for an IR then I'd be happy as larry (whoever he is).

Cutting a few ground exams out won't do jack in my opinion, with dual rates for simple SEP instrument training running at £170+ per hour.

IF a system similar to the US was introduced then significant savings could be made, and the uptake would be great - i.e. 1 written paper and reduced ground school, ad hoc training, only 15 hrs REQUIRED with an instructor, no 170A, reasonable revalidation requirement etc....

I've held an IR since 2001 and it has never lapsed. I use it too, but it is not JAR......
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Old 19th Oct 2008, 15:17
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Hence my STRONG instincts would be to ditch saving the IMCR and put all my efforts through the European Courts on the creation of a more easely achievable PPL IR for NON professional pilots.
I think you should get top notch legal advice before even thinking of going down this route.

The legal route has been tried, in certain isolated cases e.g. where the CAA has not followed proper procedures and discriminated illegally against somebody. I know of a few pilots who turned up to a medical with their solicitor... but this was in effect a threat of a judicial review. That is not the same thing as forcing through a demand for some kind of instrument qualification. IMHO this would not work because of the long established precedent where you have the "we wash your hands of you" VFR, and you have IFR for everything else.

What might work is a legal challenge to the stripping of pilot privileges by killing the IMCR. There are various precedents for that e.g. you have spent £X getting it, with a reasonable expectation of being able to keep it (by a continued meeting of checkride standards, medicals etc) and now it is being taken away.

Look at the history of previous pilot paperwork under the CAA. They have always tried to grandfather everybody into something. So if you were an old PPL instructor from the goode olde days, you got a BCPL. CAA CPLs got a free IMCR too. And so on.

Now, this extensive "we never leave you to hang out to dry" grandfathering could be because the CAA really love their customers (I am not being sarcastic) or it could be because they popped down the corridor to their legal dept and were advised that if they do such and such they will get sued. My guess is that both are true.

Under EASA, there is a threat, for the first time ever, to hang people out to dry, with no compensation.

I made some enquiries about this stuff a while ago. An Act of Parliament allows privilege stripping to be done with impunity, but a lesser body making the decision (e.g. the CAA making it in-house) does not give immunity from litigation. So if e.g. the CAA had booted out FAA licensed pilots, they could have been sued. But if this was done by a change to the ANO, they would have been protected.

AIUI, EASA regs have the same authority as the UK Parliament, so I don't see any avenue for a legal challenge on that one.

I am not a lawyer, of course.

The other side of this is: who is going to do this dirty work? AOPA UK are 99% VFR, despite most impressive London premises are dramatically under-staffed and clearly unable to take on anything big. They do have a lot of corporate members (schools) but the IMCR training income has dwindled in recent years anyway (see the tables published in FTN).

The best way IMHO is to try to preserve the FAA scene or to ensure a fair grandfathering from FAA to EASA (FCL and certification) and the best way to achieve that is the same as ever before: go for maximum political damage. So, make sure that every TP and jet operator knows what is coming. Currently, I guarantee that 99% of them haven't got a clue. I am contacting the Marketing VPs of the manufacturers right now, but there are all the owners which need to be done. These people have powerful contacts.
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Old 19th Oct 2008, 16:03
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The other side of this is: who is going to do this dirty work? AOPA UK are 99% VFR, despite most impressive London premises are dramatically under-staffed and clearly unable to take on anything big.
Sometimes you are so full of crap at times I feel the urge to throttle the living **** out of you.

Stick to pontificating on stuff that you might be able to convince others that you are talking about and leave the rest alone.

Or better still wander of and do a bit more self aggrandisement on your web site.
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Old 19th Oct 2008, 16:57
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Bose-X and IO540

Just curious....

Are you two guys of opposing associations or is it more personal?
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Old 19th Oct 2008, 17:07
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I think that sacrificing the IMCR without a real world alternative (an achievable PPL/IR or a European version of the FAA PPL/IR) would be fatal and trying to get anything like an IR-lite set up post IMC abolition would be impossible. Rather akin to trying to find a job when unemployed, or trying to find a girlfriend when you're single
WSMempson

My worry here is that saving the so called IMCR in its current form or rather how it has come to be used MAY be counterproductive! Why?

The IMCR was initially created as a get out of trouble rating. For a pure VFR pilot any level of instrument training has to increase his chances of surving in cloud.

Theoretically EASA could accept the safety benefits of incorporating instrument flying into the latter part of the PPL syllabus and achieve those safety goals by increasing the costs of achieving a PPL and by doing so making the situation more safe because all PPLs would be instrument trained.

By that path they would achieve an even greater safety result than having some PPLs with negligable instrument traing and those who now get an IMCR.

The problem is not that but how the IMCR has been used by PPLs since. They can and do takeoff into a 600 cloudbase fly out of controlled airspace for 100 odd miles and fly an Ils to a landing at their destination airport.

This is the part that will be hard to sell to EASA and there is a definate dIvision between the two aims A a get out of trouble instrument capability pilot and B the quasi mini IR that it has developed into in the UK.

NO way can you sell 15 hrs of instrument training as any form of IR to EASA.

Hence why I feel it would be better to put all efforts into a more easely NON professional PPL IR than taking the risk that EASA may accept the original concept of the IMCR and regulate to that effect and in the process IMCR Holders loose all rights to knowingly takeoff into instrument conditions while at the same time seeing a possible PPL IR evaporate in front of their eyes.

The only power we have is to persuade on the safety front for either a PPL IR or an IMCR but I Doubt we would get both.

Pace
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Old 19th Oct 2008, 17:07
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Should the IMCR be ditched in the quest for a greater prize?
Is there any evidence that this trade is on offer? But in the hypothetical situation that it were, just count how many IMCR pilots there are and how many PPL/IR pilots. On the basis of the number of pilots that might benefit, I reckon IMCR wins hands-down.

But as I say, I think this is hypothetical. Let's go for preserving IMCR and getting a more accessible PPL/IR. Let's not argue about which we want: we want both.
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Old 19th Oct 2008, 17:21
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vanHorck

I am just a private pilot and have no involvement in GA in any organisation at organisational/executive level. I write some magazine articles for one of the more specialised groups, that's all.

Feel free to PM me if you want details but the above sums it up fairly well.

Have nothing against AOPA and have never had any dealing with them. I vaguely recall that I might have been a member some years ago. I don't think UK AOPA can fund a £1M+ legal action. US AOPA just might (but obviously won't).

I have met bose-x a few times but have never had any professional or business dealings with him, aviation related or otherwise.

Pace

The IMCR was initially created as a get out of trouble rating. For a pure VFR pilot any level of instrument training has to increase his chances of surving in cloud.
This statement is being repeated over and over. But, since it is a matter of opinion and has absolutely no legal basis, I won't argue with it. The legal privileges of the IMCR are perfectly clearly defined in the ANO and have been tested over some decades, and if the CAA was unhappy with them, or felt they were improperly drafted, they have had all those years in which to change them, but they haven't.

I think the real issue is the legacy of regulations which themselves date back many decades. These define the ICAO Instrument Rating and everybody has hung their IFR coat on that hook. That hook is pretty inflexible.

However, times have moved on, flying has changed, equipment has got a lot better (for IFR) and we now have a situation where the IFR pilot has absolutely zero need to fly a perfect CAA-IR NDB holding pattern for example. I would argue that the way forward is demonstrated competence. How you achieve that, and what you call the training package, is a separate matter.

Last edited by IO540; 19th Oct 2008 at 17:42.
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Old 19th Oct 2008, 18:05
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Bose-X and IO540
Just curious....

Are you two guys of opposing associations or is it more personal?
Nope, I just get fed up of the endless spouting of ill formed opinion as if it is fact from someone who has no involvement in the process. The endless tirade about how every engineer, flight school and official is corrupt wears down even the most patient.

Writing a couple of articles for PPLIR on engine overhauls does not make one an aviation expert.

AOPA do not operate from 'grandiose premises' the have a small building which in the past would have been a house on the end of a terrace on a back street off Victoria. The ground floor is leased to Transair as a small shop and the couple of floors above house a few broom cupboard offices. The premises are owned by AOPA and therefore a minimal overhead to the membership.

Making a comment about grandiose office just proves that IO has never been to the offices. So if he is prepared to spout crap about that, how are we supposed to take anything else he takes seriously?

If you hate aviation that much peter why don't you piss off and take up golf?
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Old 19th Oct 2008, 18:47
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bose-x, for heavens's sake, as someone who purports to represent AOPA in certain areas, will you please moderate the intemperate and offensive tone of your posts.......
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Old 19th Oct 2008, 19:13
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The really interesting thing is that bose-x's name (which I obviously know) does not feature on the list of AOPA officers here.
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Old 19th Oct 2008, 19:58
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OK so back to the thread gentlemen?

PACE, don't even think about going down some kind of legal challenge route. Trust me, I AM a lawyer!

The only way of sorting this mess out has got to be lobbying and more lobbying.

So I guess we need to support those who are working their socks off for us on this - and other issues.

And to those of you who don't seem keen on AOPA. Yes, nobody is perfect, but it seems to me that AOPA is the best chance we've got - so shouldn't we all get behind them? And even join, IMHO.
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Old 19th Oct 2008, 21:32
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bose-x, for heavens's sake, as someone who purports to represent AOPA in certain areas, will you please moderate the intemperate and offensive tone of your posts.......
You are quite right of course Beagle. Sometimes the crap makes my blood boil.

Oh and Peter, I have never claimed to be an 'officer' of AOPA. I am merely a member of the organisation who has volunteered his services in order to help preserve our rights as pilots. Something that I am passionate about and prepared to commit my time efforts and expertise to the cause. Whereas it strikes me that you just prefer to deride and under mine the efforts of those who choose to try and do something. Oh and attending one meeting at the CAA on behalf of Fuji's IMCR campaign does not count as putting anything worthwhile into the pot IMHO.

But hey because I am not an 'officer' of AOPA I perfectly entitled to express my own opinion. Be interesting to see you identify the people on here who are 'officers' of AOPA though. The results would be interesting.

So in a more conciliatory tone, why don't you try and expend some of your very significant energy on actually trying to change something rather than just enthralling us all with your expert opinion. Someone who knows as much as you do and obviously mixes with the movers and shakers in aviation would be a powerful asset to any organisation. The MWG would benefit from channelling your energy into the good cause rather than just about it. Therefore this is an open invite for you to have a seat at the table.

You know where to find me.
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Old 19th Oct 2008, 21:54
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EASA is currently setting up a work group, FCL.008, to consider the issues of the IR, IMCR and glider cloud flying qualification. This is as heralded earlier this year. The TORs are not yet in the public domain. Nomination of experts to this group is under way, and from the GA community - across Europe, not just UK of course - nominations can only be made through either IAOPA, Europe Air Sports (EAS) or ECOGAS. Deadline for nominations is Wednesday.

I have liaised with he CEO of AOPA (UK) to try and make sure we make the best of the opportunity of nominating, through our pan EU organisations, the most appropriate people. Who must not just be experts in the subjects but also have the time available and the right attributes to influence the outcome. EAS will be nominating several leading experts who can cover all aspects of the TORs, including the IR issue.

On a related matter, EAS is very active on the political and semi-political front in Europe, with the assistance of our professional, Brussels-based, adviser (lobbyist, but we don't use that term). We have already scored several successes but do not publicise these until the game is over (i.e. the law is embedded) to avoid the risk of not winning the final points in the match.

Wearing my EAS hat, along with our President, we have a top level meeting this week in the UK with the real decision makers at the heart of Europe, and the topics in this thread are very much at the centre of the agenda.

It is interesting reading these threads but at the end of the day what matters is how the processes in Europe are influenced directly by the people who represent GA, mostly behind the scenes. Those from the UK come from a broad cross section of GA activity and are well informed. Forget legal challenges - it would be a waste of effort and money. Time spent understanding the mindsets of other EU countries (i.e. the Member States and their officials) is more productive.
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